SCRUTINY COMMITTEE
Wednesday, 23rd May, 2012
10.00 am
Darent Room, Sessions House, County Hall, Maidstone
AGENDA
SCRUTINY COMMITTEE
Wednesday, 23rd May, 2012, at 10.00 am Ask for: Anna Taylor Darent Room, Sessions House, County Telephone: 01622 694764 Hall, Maidstone
Membership
Conservative (7): Mr R F Manning (Chairman), Mr B R Cope, Mr D A Hirst, Mrs S V Hohler, Mr R A Marsh, Mr J E Scholes and Mr C T Wells
Liberal Democrat (1): Mrs T Dean
Labour (1) Mr G Cowan
Independent (1) Mr R J Lees
Church Dr A Bamford, The Reverend N Genders and Mr A Tear Representatives (3): Parent Governor (2): Mr P Myers and Mr B Critchley
Refreshments will be available 15 minutes before the start of the meeting Timing of items as shown below is approximate and subject to change. County Councillors who are not Members of the Committee but who wish to ask questions at the meeting are asked to notify the Chairman of their questions in advance.
Webcasting Notice
Please note: this meeting may be filmed for live or subsequent broadcast via the Council’s internet site – at the start of the meeting the Chairman will confirm if all or part of the meeting is being filmed.
By entering the meeting room you are consenting to being filmed and to the possible use of those images and sound recordings for webcasting and/or training purposes. If you do not wish to have your image captured then you should make the Clerk of the meeting aware.
UNRESTRICTED ITEMS (During these items the meeting is likely to be open to the public)
A - Committee Business A1 Introduction/Webcast announcement
A2 Substitutes
A3 Election of Vice Chairman
A4 Declarations of Interests by Members in items on the Agenda for this Meeting
A5 Minutes of the meeting held on 29 March 2012 (Pages 1 - 2)
B - Any item placed on the agenda by any Member of the Council for discussion B1 Hawkinge Household Waste Recycling Centre Consultation (Pages 3 - 106) Item from Ms Carey
Following Cabinet’s agreement to proposals set out in a report on 19 March 2012 Mr Sweetland took a decision on 3 April 2012 to agree changes to both the operating policy and the network infrastructure of the Household Waste Recycling Centres provided by Kent County Council, this included the closure of the Hawkinge household waste recycling centre.
Ms Carey has indicated that she wishes to raise the following points:
1. Out of date figures were being used;
2. Hawkinge is the only site not open at weekends;
3. No statistical information was available as to the number of users;
4. The figures quoted by way of savings appear to include costs which would be transferred to alternative sites upon closure; and
5. The public questionnaire was biased in the way Hawkinge was referred to.
EXEMPT ITEMS (At the time of preparing the agenda there were no exempt items. During any such items which may arise the meeting is likely NOT to be open to the public)
Peter Sass Head of Democratic Services (01622) 694002
Tuesday, 15 May 2012
Please note that any background documents referred to in the accompanying papers maybe inspected by arrangement with the officer responsible for preparing the relevant report.
This page is intentionally left blank Agenda Item A5
KENT COUNTY COUNCIL
SCRUTINY COMMITTEE
MINUTES of a meeting of the Scrutiny Committee held in the on Thursday, 29 March 2012.
PRESENT: Mr B R Cope, Mr G Cowan, Mrs T Dean, Mr D A Hirst, Mrs S V Hohler, Mr R F Manning, Mr R A Marsh, Mr J R Bullock, MBE (Substitute for Mr J E Scholes) and Mr M J Jarvis (Substitute for Mr C T Wells)
ALSO PRESENT: Mrs P A V Stockell
IN ATTENDANCE: Mr P Sass (Head of Democratic Services)
UNRESTRICTED ITEMS
1. Membership (Item 1)
The Committee noted its Membership as set out on the agenda.
2. Election of Chairman (Item 3)
(1) Mr G Cowan proposed and Mrs T Dean seconded that Mrs T Dean be elected Chairman. On being put to the vote this proposal was lost.
(2) Mr D A Hirst proposed and Mr B R Cope seconded that Mr R F Manning be elected Chairman. On being put to the vote this proposal was carried.
(3) RESOLVED that Mr R F Manning be elected Chairman of the Committee.
Page1 1 This page is intentionally left blank
Page 2 Agenda Item B1
By: Peter Sass: Head of Democratic Services
To: Scrutiny Committee – 23 May 2012
Subject: Hawkinge Household Waste Recycling Centre Consultation
Background
(1) Following Cabinet’s agreement to proposals set out in a report on 19 March 2012 Mr Sweetland took a decision on 3 April 2012 to agree changes to both the operating policy and the network infrastructure of the Household Waste Recycling Centre provided by Kent County Council, this included the closure of the Hawkinge household waste recycling centre.
(2) In accordance with the terms of reference of the Scrutiny Committee, Ms Carey has exercised her right to place the issue of the consultation undertaken in relation to the decision to close the Hawkinge household waste recycling centre on the agenda of the Scrutiny Committee.
(3) Any Member has a legal right to place an item on the Scrutiny Committee agenda. In this case, Mr Sweetland’s decision is not being ‘called in’ and therefore its implementation cannot be delayed or overturned by it being placed on the Scrutiny Committee agenda. The Committee may decide, however, to make comments or recommendations to the Cabinet Member for his consideration and response.
Documents
(4) The Chairman has determined that the following reports be attached:
• Decision report attached at Appendix A.
• Cabinet Report attached at Appendix B.
• Public Consultation Report attached at Appendix C.
• Equalities Impact Assessments attached at Appendix D.
Guests
(5) Mr B Sweetland, Cabinet Member, Environment, Highways and Waste has been invited to attend the meeting for this item.
Page 3 Options for the Scrutiny Committee
(6) The Scrutiny Committee may:
(a) make no comments
(b) express comments but not require reconsideration of the decision
Contact: Anna Taylor Tel: 01622 694764
Page 4 Appendix A
Page 5 Page 6 Page 7 Page 8 Appendix B
By: Bryan Sweetland, Cabinet Member for Environment, Highways and Waste Mike Austerberry, Corporate Director, Enterprise and Environment
To: Cabinet 19 March 2012
Subject: Review of Household Waste Recycling Centres and Future Service Delivery
For Decision
Classification: Unrestricted
Summary: This report sets out the findings of the Review of the Household Waste Recycling Centres (HWRCs) in Kent and recommends changes to the way the sites are to be operated and provided.
1. Introduction and Review Process
1.1 On 8th April 2011 the Environment Highways and Waste Policy Overview and Scrutiny Committee (POSC), agreed the terms of reference of a review of the Household Waste Recycling Centre (HWRC) service. The POSC agreed that an Informal Member Group (IMG) should guide the review. The Informal Member Group comprised: Councillors John Cubitt (chair), Mike Harrison, Steve Manion, Malcolm Robertson, and Elizabeth Tweed
1.2 The Informal Members Group reported the review findings back to POSC on 27 September 2011. The Committee supported the findings and referred the matter for public consultation.
The report from the Informal Members Group considered in detail the options for change relating to the operating policy of the sites and the household waste recycling centre network. The financial implications of the changes were confirmed as being consistent with the medium term financial plan and the current capital programme.
It was resolved that the recommendations of the Informal Members Group were supported.
Page 9
1.3 Following the end of the public consultation on 9 February 2012, the Informal Members’ Group met on 21 February 2012 to consider the outcomes, which have led to the recommendations in this report.
1.4 This decision report is structured as follows.
Section Heading Page No. 1 Introduction and Review process 1 2 Current arrangements 2 3 Public Consultation & Equalities Impact 4 Assessment 4 HWRC: Operating policy 4 5 HWRC: Current network provision 9 6 HWRC: Future network provision 13 7 Operational Risk Management 18 8 Financial Considerations 19 9 Recommendations 19
2. Current arrangements
2.1 As the waste disposal authority for Kent, Kent County Council has a statutory obligation under the Environmental Protection Act 1990
“for places to be provided at which persons resident in its area may deposit their household waste and for the disposal of waste so deposited”.
There is no duty to receive trade waste and the household waste recycling centres are not licensed to do so.
2.2 The Act does not specify how many sites, the ratio of sites to households, or travel times. Most of the population of Kent is within a 20 minute drive of a HWRC.
2.3 Kent has 19 HWRCs, of which 6 are co-located with waste transfer stations. The sites are located largely as a reflection of historic factors, particularly in respect of those locations which are associated with closed landfill sites. Their distribution does, however, broadly reflect the centres of population in the county.
2.4 Map 1 below shows the network of transfer stations and household waste recycling centres across Kent with drive times.
Page 10
Page 11
Map 1: Location of Household Waste Recycling Centres and Waste Transfer Stations, including journey times.
3. Public Consultation and Equalities Impact Assessment
3.1 Following the POSC meeting on 27 September 2011, a 10 week public consultation commenced on 1 December 2011 and ran until 9 February 2012 on options for change. A total of 3,499 responses were received; 3,456 from the general public and 43 from stakeholders. There were 2056 on-line responses and 1,400 hard copy responses.
3.2 A full Equalities Impact Assessment (EIA) was conducted prior to the development and delivery of the public consultation. This shaped the engagement and participation mechanisms, and identified Protected Characteristics which have the potential to be positively or negatively impacted by the proposed policies. This also ensured that particular attention was paid to engagement with minority groups in Kent.
3.3 The methodology for the consultation aimed to engage householders across all sectors of Kent’s communities, providing residents with the opportunity to participate in the consultation. Of the 3,095 hard copies of the questionnaire distributed, 1,400 were returned; a 45% response rate. There were responses from 28 of the 305 Town and Parish Councils and 8 responses from the waste collection authorities.
3.4 A further EIA was undertaken following the consultation, confirming impacts already identified in the initial screening and interim EIA. Assessments will continue to monitor customer usage and feedback following the implementation of any policy changes, with appropriate action to be taken as required.
4. Household waste recycling centres: Operating policy
4.1 The key policy areas are considered below. These are:-
Ø Limiting the materials coming into the sites; and Ø Limiting trade waste and non-Kent vehicles
Each is provided with a commentary on the original IMG/POSC position and a summary of the consultation response, as applicable.
4.2 The IMG was mindful that any operating policy changes would require sufficient communication to ensure that the public were aware of the changes. This has been reinforced through the EIA and is considered later in the report. In considering operational changes the IMG was also mindful that interventions which tended to reduce queues at HWRCs would help alleviate pressure on the sites, and respond to the public’s on-going concerns about queues.
4.3 The efficiencies being taken forward recognise the difference in approach needed in respect of the fixed costs, predominantly in operating the sites, and the variable costs of disposal of the waste tonnage arisings. The variable costs are by far the larger element.
Page 12 4.3.1 Limiting the materials coming into the sites
POSC report:
Having in mind that the greatest cost in managing waste through the HWRCs is the treatment/disposal of the waste brought into the sites rather than the operating costs of the sites, the exclusion of non-household waste was seen as a priority by IMG. The IMG therefore focused in detail on tyres, asbestos and gas bottles.
It was proposed to:
a) exclude all tyres on the basis that householders were unlikely to change tyres at home; b) exclude asbestos as the amounts being received were inconsistent with householder’s arisings and were very likely to be the spoil from demolition; c) exclude gas bottles which are generally subject to re-use. (Small single- use gas containers would still be accepted.)
The IMG noted that construction waste in quantities clearly in excess of that which could be related to domestic DIY, were being deposited at the HWRCs on a daily basis. Even though hardcore and other materials could be recycled the IMG considered the processing cost of £400k per year to be excessive. It proposed to exclude construction waste.
The IMG was aware that at the same time alternative disposal routes would be required (albeit at a charge) and that this should be encouraged through both private and KCC owned waste transfer stations.
Consultation responses summary :
Do you consider that items such as tyres, gas bottles, and asbestos, which are mainly commercial waste, should be excluded from HWRCs, provided that other routes are available?
60% agreed, 32% disagreed and 8% answered don’t know. The four most recorded comments were: Ø Materials may be fly-tipped Ø Believe that these materials are generated by householders and they have a need for the HWRCs to accept them Ø Customers want a one-stop-shop for all materials and convenience of service Ø Lack of information about other disposal routes
Would you support the exclusion of construction waste, which the HWRCs have no duty to accept and costs the Council money?
65% agreed, 26% disagreed and 9% answered don’t know The four most recorded comments were: Ø Increase in fly-tipping Ø Penalises “the DIY person” Ø Should charge for all construction waste regardless of source Ø Lack of information about alternative disposal points Page 13 Revised recommendations taking account of consultation and EIA:
The majority of respondents support change and agree that the material is mainly commercial waste. The comments support the need to implement the changes in a systematic way.
(i) Tyres, asbestos and gas bottles
It is now proposed that these items/waste are accepted at waste transfer stations only, and the unit quantity limited as follows.
Tyres: Limit car tyres to a maximum of two per visit. Asbestos: Limited to one sack or equivalent per visit. Gas bottles: Limited to one gas bottle per visit.
Additionally a charging regime is now proposed for this waste, with a standard charge of £5 per unit (i.e. up to 2 tyres or one bag of asbestos or one gas bottle). This charge is set to be increased annually as necessary to cover any increase in disposal costs and administration. The consultation indicated that there was a need for the Council to consider ways to continue to provide this service, and a charge to cover disposal and administration costs would enable this need to be met.
(ii) Construction waste
It is proposed that the amount of household waste to be brought into a site by any single vehicle, or combined vehicle and trailer, is to be a maximum of one car boot load of household construction waste. This is equivalent to 3 bags, of up to 30kg weight per bag, being a weight that the average person can lift. (For example - the bags are to be similar in size to a large sack of compost). The waste is to comprise spoil, hardcore, soil, rubble, or equivalent. For larger items such as baths, the material would not need to be bagged but should not exceed approx. 90kg in total or one average car boot load per visit. There is to be no limit on repeat visits as this is unenforceable across the network.
It is clear that this approach would bring the service in line with standard practice for most other waste disposal authorities, reducing arisings from the current disproportionately high levels as shown below.
Construction Waste Overview
Kg/household 2010/11 Kent Medway Surrey East Sussex Total HWRC waste arisings 310 262 300 246.5 HWRC Residual waste 92.7 166.32 123.38 112.08 Soil hardcore 70.65 10.89 36.48 24.01 Soil/Hardcore % of total arisings 22.7% 4.2% 12.2% 9.7% Source: DEFRA Waste Data Flow
The IMG was mindful that capacity must be provided for commercial waste to ensure proper disposal and to prevent fly-tipping. Clearly, there is a demand for cost-effective disposal of commercial waste, particularly from businesses which produce relatively small quantities of waste and/or produce
Page 14 waste on an irregular basis. The waste transfer network of 6 sites is designated for charged-for waste. The transfer stations are provided with weighbridges linked to invoicing software, and are capable of producing waste transfer notes to comply with the waste Duty of Care Regulations. It is proposed that the waste transfer stations are provided and adapted as necessary to handle the tonnage of trade waste which may be displaced from the household waste recycling centres, so that this waste can be properly handled at a realistic charge.
(iii) Customer information programme
A comprehensive customer information programme regarding disposal options for these materials is proposed in advance of implementation and on a continuing basis.
(iv) Implementation of operational policy changes
It is proposed that the Corporate Director for Enterprise and Environment implements the roll-out of the policy changes regarding limiting materials in a systematic way, through a phased approach to ensure sufficient capacity to manage a smooth transition and to keep progress under continuous review to maximise customer service.
4.3.2 Trade and non-Kent Vehicles
POSC Report
The IMG was shocked to note the extent of trade waste being delivered on its sites’ tour. The IMG felt that a blanket ban on all trade or potentially trade vehicles and trailers was necessary, with an exception scheme available only in very rare circumstances. The IMG also noted that some householders from Kent use the Cuxton, Medway site and that conversely, some Medway residents visit Pepperhill and other KCC facilities.
In respect of the county’s western border, a permit scheme was proposed for the sites in proximity to the border, namely Dartford Heath, Swanley, Dunbrik and New Romney, in order to restrict usage to Kent householders.
Consultation responses summary :
Would you support the exclusion of trade waste e.g. by ceasing to open the height barrier and excluding trade vehicles, which the HWRCs have no duty to accept and costs the Council money?
67% agree, 25% disagree and 8% answered don’t know The five most recorded comments were:- Ø Increase in fly-tipping Ø Implement a charging scheme for traders Ø What about householders who only have a van or hire a van. Ø Allow all waste from anyone to save fly-tipping and generate income Ø Encourage all waste to be disposed of responsibly
Page 15
Do you believe that it is reasonable for householders who do not live in Kent, and therefore do not contribute to funding of the sites, to be excluded from using Kent’s HWRCs?
59% agree, 34% disagree and 7% answered don’t know The three most recorded comments were: Ø Reciprocal arrangements are required, balance needed, petty proposal Ø Risk of fly-tipping Ø Convenience to use nearest HWRC regardless of border
Do you use HWRCs in other areas?
92% answered yes and 8% answered no. Of those that use sites in other areas, 57% use Medway sites
Revised recommendations taking account of consultation and EIA:
The majority of respondents support change, subject to an exception scheme in limited circumstances. Exclusion of commercial vehicles will reduce queues and congestion on sites, which has been repeatedly raised as an issue in consultation responses.
(i) Commercial vehicles
It is proposed that all commercial vehicles, including vans and pick-up trucks of any size, and agricultural vehicles including horse-boxes, are to be excluded. For the purposes of defining a commercial vehicle the definition applied by HM Revenue and Customs will be applied.
An exception scheme for customers with disabilities will be provided. In addition a permit scheme for the minimal number of householders who do not own any other vehicle other than an excluded vehicle, and those with large private vehicles (which cannot fit under the height barriers) will be established at nominated sites. All other conditions, such as the limit on construction waste, will apply. The permit scheme will provide access to the sites on up to 12 occasions per calendar year. Any exceptional application for further permits within a single year will be investigated to ensure the exclusion of trade waste.
The IMG was mindful that capacity for commercial waste must be provided to ensure proper disposal and to prevent fly-tipping. Clearly, there is a demand for cost-effective disposal of commercial waste, particularly from businesses which produce relatively small quantities of waste and/or produce waste on an irregular basis. The waste transfer network of 6 sites is designated for charged-for waste. The transfer stations are provided with weighbridges linked to invoicing software, and are capable of producing waste transfer notes to comply with the waste duty of care regulations. It is proposed that the waste transfer stations are provided and adapted as necessary to handle the tonnage of commercial waste which may be displaced from the household waste recycling centres, so that this waste can be properly handled at a realistic charge. If there is insufficient capacity further interventions may be required to ensure additional outlets. Page 16 (ii) Trailers
Although there is a risk that a minority of traders may utilise trailers to access the HWRCs, it has been recognised that there is a genuine need by householders to use trailers in certain circumstances. Consequently, trailers are to be limited in size to approximately 1.0m3 capacity, to assist householders, and for ease of manoeuvring on site. For clarity, the total combined quantity of construction waste is to be limited to 1.0m 3 and not to be doubled for a combined vehicle and trailer.
(iii) Western Boundary
The existing permit scheme at Dartford Heath HWRC is to be retained. A permit scheme for Kent residents at other sites near the county’s western boundary is not recommended, but a trial permit scheme is to be considered for the Swanley site in order to test value for money. It was considered that the cross-border movement of household waste was likely to be broadly similar in each direction, but this should be tested.
(iv) Provision for Trade Waste
As a pre-requisite for the exclusion of construction and trade waste from household waste recycling centres, it is necessary to support the development of additional commercial capacity where there is evidence of under-provision of waste disposal for businesses. Collaboration with the Minerals and Waste Development Framework project will be valuable in taking this forward. Additionally a feasibility study is proposed on the opportunities at Kent County Council’s waste sites to promote cost-effective waste disposal capacity for businesses in order to ensure there are alternatives to fly-tipping.
(v) Implementation of operational policy changes
It is proposed that the Corporate Director for Enterprise and Environment implements the roll-out of the policy changes regarding trade waste in a systematic way, through a phased approach to ensure sufficient capacity to manage a smooth transition and to keep progress under continuous review to maximise customer service.
5. Household Waste Recycling Centres: Current network provision
POSC Report
5.1 It was considered that the design-build-finance-operate model, widely used in the waste industry, has become less attractive during the recession as the cost of private sector borrowing increased.
5.2 The IMG noted that in earlier years, capital funding for waste infrastructure had been provided primarily by Government grant, namely Waste Infrastructure Capital Grant (WICG). This funding was spent necessarily on projects with high deliverability, leading to some projects being deferred such as those with challenging waste planning permission issues. Page 17
5.3 It was clear that there had been significant investment in the past and that this should be sustained. The recent investment at Pepperhill and Manston Road, Margate sites was noted, together with the additional household waste recycling centre opened at New Romney in 2011, as evidence of continuing investment by the Council.
5.4 The Table below shows the current capital provision for waste management infrastructure.
TOTAL Previous WASTE CAPITAL Forecast Total Years 2010-11 2011-12 2012-13 PROGRAMME Future Scheme Spend Spend Budget Budget Years Costs
£'000s Herne Bay Site Improvement 95 0 250 1250 0 1,595 New Romney - New site 520 1,475 32 0 0 2,027 development Sub-total 615 1,475 282 1250 0 3,622 Transfer Stations Improvements TS/HWRC Swale 0 0 0 1,880 1750 3,630 TS/HWRC Ashford 0 0 750 4,250 0 5,000 TS/HWRC Tunbridge Wells 50 242 881 0 0 1,173 HWRC Mid Kent (TMBC) 0 0 0 0 2300 2,300 HWRC West Kent 0 0 0 0 2600 2,600 sub-total 50 242 1,631 6,130 6,650 14,703 Total Waste Capital 665 1,717 1,913 7,380 6,650 18,325 Programme
Page 18 5.5 In order to plan effectively it is important to consider the network as a whole rather than prioritise opportunistic advances. It is also necessary to take account of growth and regeneration, the significant improvements in the highway network in Kent over the past 30 years, and the extent to which existing facilities meet current demands and standards. In particular, irrespective of the standard of the actual sites, the IMG noted serious access issues at several facilities such as Church Marshes, Sittingbourne.
5.6 With this in mind, the existing network of 19 sites has been divided into 6 zones or clusters. The IMG considered that this approach should provide the blueprint for future network delivery.
These clusters are:
1. SE Kent: Dover, New Romney, Shornecliffe, Hawkinge & Ashford
2. NE Kent: Canterbury, Herne Bay, Margate, Deal and Richborough
3. Swale: Sheerness, Sittingbourne and Faversham
4. NW Kent: Pepperhill, Dartford Heath and Swanley,
5. Mid Kent Tovil (Cuxton),
6. W Kent: Sevenoaks and Tunbridge Wells
There are proposals for clusters 1-5, but no proposal for (6) W Kent as these two waste transfer station and household waste recycling centre sites will be reviewed ahead of their existing management contract terms.
Page 19 Page 20
6. Household Waste Recycling Centres: Future network provision
This section identifies potential scope for optimisation of the network within the clusters. The consultation first included general questions regarding usage and options for change with the following responses.
Ø 85% of the respondents rate the current service as good or excellent. Ø 40% of respondents visit the HWRCs a few times a year, 10% visit weekly, 22% visit 2-3 times a month and 24% visit monthly. Ø 91% of respondents have a journey time of less than 20 minutes to their nearest HWRC. Ø 71% of respondents believe that a reasonable drive time to a HWRC is between 10 and 20 minutes.
Specific questions and responses are set out below.
Thinking of the Council’s aim to continuously improve sites, do you believe that the HWRCs are generally fit for purpose?
90% agree, 5% disagree and 5% answered don’t know The three most common comments were: Ø HWRC too small and poorly designed Ø Negative experience of queues Ø Need to increase materials streams
Would you support an overall reduction of one or two sites across Kent, provided the service continued to be operated to a good standard across the remainder of the HWRCs?
55% agreed, 30% disagree and 15% answered don’t know
To help shape the future of the network of HWRCs, please tell us which are the three most important things for you?
The top most important factors were the range of materials, short journey times and reduced queues.
If you do not use a Kent HWRC, are there any improvements that would encourage you to? (Note – some respondents answered this question although they do use the HWRCs already)
The top 3 reasons were stated as: Ø Local facilities – want a site close to home Ø Extend range of materials accepted Ø Improve accessibility, no steps to containers.
Page 21
Turning to the clusters identified in section 5.6 above, each one is considered separately below.
SE Kent Dover, New Romney, Shornecliffe, Hawkinge and Ashford
POSC Report
The plans for a new transfer station at Ashford provide an opportunity to improve access and upgrade the HWRC substantially. The accepted business case includes the associated closure of the legacy transfer station and HWRC at Hawkinge, which is located at the site of an obsolete incinerator. The Hawkinge site is set to close when the Ashford facility comes on stream in 2013. It is considered that the remaining sites in the zone meet current needs and standards. However in the long-term, consideration may need to be given to the need for expansion or relocation of the Shornecliffe (Folkestone) HWRC which has limited capacity to meet any increase in demand.
Consultation response summary :
Taking into account proposals to improve the facility at Ashford, do you believe it is reasonable to close the out of date and expensive to operate site at Hawkinge, provided services exist within a 20 minute drive time of your home?
36% agreed, 18% disagreed, 46% answered don’t know The three most common comments were: Ø Other HWRCs are too far to travel Ø Improve Hawkinge HWRC Ø Increased fly-tipping
204 people from the Hawkinge area responded that the HWRC should not be closed.
The most commonly stated reasons were: Ø Increased journey times Ø Fly-tipping increase Ø Hawkinge is a growing town and needs its own HWRC
Some respondents commented that the question was loaded and/or misleading.
Petition
A petition of 587 signatures was presented by Hawkinge Town Council to the Cabinet Member on 22 February 2012 strongly opposing any proposal to close the household waste recycling centre at Hawkinge.
Do you support the upgrading of the existing HWRC at Ashford, which forms part of the proposal for a new waste transfer station?
Page 22
50% agree, 4% disagree and 46% answered don’t know Of those respondents who use the Ashford HWRC 88% support upgrading.
Revised recommendations taking account of consultation and EIA:
It is proposed to close Hawkinge HWRC and waste transfer station in late 2013 as part of the proposal to provide a new waste transfer station at Ashford. This takes account of the site having the lowest waste arisings of any site in the county, the nature of the legacy site which opens on weekdays and on a Saturday morning only for historic reasons, the ongoing cost of maintaining the obsolete incinerator building and the availability of both Shornecliffe, Folkestone and Whitfield, Dover HWRCs within a 20 minutes drive time.
NE Kent Canterbury, Herne Bay, Margate, Deal & Richborough
POSC Report
This zone has sites in close proximity, each serving discrete populations (with the exception of Richborough HWRC, where the hinterland for the site overlaps with that of Margate HWRC). The Richborough site has limited space and would need significant investment for expansion and upgrading to modern standards. Therefore, Richborough HWRC has been identified for closure in summer 2013, when the current management contract expires. The nearest alternative site is at Margate, which was subject to major re- development and expansion in 2006. It has available capacity to meet any resultant increased demand, and mapping analysis shows the impact on householders’ drive times would be minimal.
Of the other three sites, Canterbury HWRC is a modern fit for purpose site serving a large urban community; Herne Bay HWRC is scheduled for major re-development to current standards in 2012; and Deal HWRC (although relatively small) provides a full range of services and serves a distinct local community.
Consultation response summary :
Taking into account that there is a facility at Deal and Margate, do you believe it is reasonable to close the out of date and expensive to operate facility at Richborough, provided services exist within a 20 minute drive time of your home?
41% agree, 17% disagree and 42% answered don’t know. The three most common comments were: Ø Other HWRCs are too far to travel Ø The roads do not make other HWRCs easily accessible. Ø The HWRC is always busy and should not be closed
Page 23
177 people from the Richborough area responded that the HWRC should not be closed. The most commonly stated reasons were: Ø Journey times will increase Ø Increase in fly-tipping Ø The site should be updated / improved
E-petition
An e-petition commenced on 14 February 2012, petitioning the Council “to decide to keep the household waste recycling centre at Richborough” on the stated basis that it is a well-run site, used by local residents, any closure will increase pressure on other sites and increase fly-tipping.
Revised recommendations taking account of consultation and EIA:
It is proposed to close Richborough HWRC in 2013 (when the current management contract expires) due to its low waste tonnage throughput, the poor quality of the site which would otherwise require significant capital investment, and the low number of households which would be affected by drive times to the next nearest site.
Swale Sheerness, Church Marshes and Faversham
POSC Report
The three sites in this area were developed in the 1980s and have had little further capital investment. They are arguably no longer fit for purpose, being too small to be capable of significant improvement. The existing capital programme already makes provision to replace the Church Marshes transfer station and HWRC. It is important to consider the context of the recent highway investment to Sheerness, the new Sittingbourne Northern Relief Road currently under construction, and proposals for regeneration in the area by Swale Borough Council. With these points in mind, once the Church Marshes relocation site is confirmed it will be possible to consider any scope for consolidation in this zone.
Consultation response summary :
Do you agree that the HWRC at Church Marshes, Sittingbourne, is inadequate and should be replaced with a new facility at a more accessible location, to provide a more efficient service to Swale residents?
24% agree, 4% disagree and 72% answered don’t know.
Of the respondents who use Church Marshes 40% believe it should be replaced. The most common comments from those who disagree with replacement were: Ø Happy with Church Marshes as it is
Page 24
Ø This will result in the closure of Faversham or Sheerness sites Ø Not enough information on new location
Revised recommendations taking account of consultation and EIA:
It is proposed that a site search be carried out to find a replacement site for Church Marshes TS/HWRC. Subject to the location of the replacement site, it is proposed site provision in the area be reviewed and consult on any further changes which are indicated. ______
West Kent Pepperhill, Dartford Heath and Swanley,
POSC report
Pepperhill transfer station and HWRC opened in 2008 has been subject to major investment. It is subject to a long term management contract. It is one of the busiest sites in the Kent HWRC network. Of the other two sites, Dartford Heath is on land which is leased and therefore produces an additional revenue pressure. However, based on tonnage throughput and operating cost, these two smaller sites, Dartford Heath and Swanley, are considered to be cost-effective. As a result the time to consider the future of these two sites is at the lease expiry in 2017.
Consultation response summary :
The HWRCs at Dartford Heath and Swanley currently operate at full capacity with no scope for expansion. Do you agree they should be replaced with modern facilities?
50% agree, 6% disagree and 44% answered don’t know Of the respondents who use Dartford Heath and Swanley HWRCs, 47% believe they should be replaced with modern facilities. The three main reasons why people disagreed were: Ø The sites are fine as they are Ø Risk of reducing from two sites to one Ø Insufficient information
Revised recommendations taking account of consultation and EIA:
It is proposed a site search be carried out in this area, with a view to replacement facilities being provided in 2017, and subject to a further decision. A provision of £2.6m has already been made in the waste capital programme.
Mid-Kent Tovil (Cuxton)
POSC Report
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Tovil HWRC is recognised as an over-subscribed site. It serves the whole of the Maidstone urban area, the West Malling / Larkfield / Ditton corridor, and a large proportion of the rural area to the south reaching to the county boundary at Hawkhurst. There is a clear need for an additional site to reduce the pressure at Tovil and equally seek to provide a service for Tonbridge and Malling Borough Council area residents.
Additionally, KCC pays Medway for KCC householders’ use of the Medway Cuxton site. This funding of £300k per year would be better used to support a new facility in Kent. The capital programme previously made provision for this project but the funding was removed due to the problems finding a suitable site. It is proposed that the site search be renewed and new capital funding sought for development in 2015/16, subject to the pressure on the capital programme.
Consultation response summary :
Do you support the provision of an additional HWRC in the Tonbridge and Malling area, which is currently not covered by the existing network?
52% agree, 3% disagree, 45% answered don’t know
Stakeholder comments included: Ø Support for an HWRC in the area Ø Improve existing access before building new ones Ø Overcrowding at sites e.g. Tovil
Revised recommendations taking account of consultation and EIA:
Despite previous unsuccessful site searches it is proposed to continue to seek to provide a new site to serve Tonbridge and Malling and Maidstone residents which will assist in reducing queues to the Tovil HWRC. Provision of £2.3m has been included in the capital programme.
7. Operational risk management
7.1 Fly-tipping
7.1.1 Fly-tipping has been identified as a risk consequent to both operational changes and site closures. However, the vast majority of Kent residents are law abiding and keen to recycle and dispose of their waste appropriately. When individual household waste recycling centres have been closed for refurbishment in the past there has been no evidence of increased fly- tipping. For instance the Pepperhill site, one of the busiest in the county, was closed for 6 months in 2008 without any adverse impact in this respect. Additionally, in other local authority areas where radical changes have been made which far exceed those proposed in this report, any temporary increase in fly-tipping has been short-lived.
7.1.2 However, it is recognised that there is a minority of people who commit criminal offences. The Council, working with the waste collection authorities, has a very good track record of successful prosecutions utilising covert Page 26
surveillance to secure significant fines including custodial sentencing. The maximum penalty of 5 years in prison and fines of up to £50,000 is well established. The team also pursues cases of fraud where waste entering the HWRCs is misrepresented as household waste. It works regionally with London boroughs, the Environment Agency and the waste collection authorities to share intelligence.
7.1.3 It is proposed to launch a new campaign to increase vigilance and emphasise a zero-tolerance approach to fly-tipping across the county which coincides with the proposed operational changes. The campaign will aim to maximise the deterrent impact of criminal prosecutions across Kent.
7.1.4 In respect of managing the risk of fly-tipping, it is important to ensure that the commercial and industrial (C&I) waste sector is provided with information on their current disposal options as part of the customer engagement plan highlighted below. Additionally, the Minerals and Waste Development Framework is making provision for all commercial and industrial waste arisings in the County. A network of suitable sites is currently being identified as part of the site assessment process. The preferred options for new sites will be consulted on in a consultation commencing at the end of May 2012. In addition KCC will be safeguarding the existing major facilities for commercial and industrial waste in the Core Strategy in order to maintain capacity for the planned period to 2030.
7.2 Customer Engagement Plan
7.2.1 The need for a comprehensive customer engagement plan ahead of the implementation of any agreed operational changes was noted by the IMG/POSC as essential. Attention is particularly drawn to a recurring point in the Equalities Impact Assessment which is the need for appropriate communications, for instance in relation to the protected characteristics of age, disability, race, and pregnancy & maternity.
7.2.2 There will need to be a planned implementation programme so that information can be provided during the lead-in period. A phased approach will be taken to manage the transition, with good communications to raise public awareness of changes in the way sites are operated.
8. Financial considerations
8.1 The proposed operational and infrastructure changes will deliver efficiencies and are consistent with the medium term financial plan. Additional funding has already been provided within the capital programme for waste management infrastructure.
9. Recommendations
9.1 It is recommended that Cabinet agree that the following operational policy changes are made at the household waste recycling centres.
a) Tyres, asbestos and gas bottles are to be accepted by KCC’s network of waste transfer stations only , and the quantity limited as follows.
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Tyres: Limit car tyres to a maximum of two, per visit. Asbestos: Limited to one sack or equivalent, per visit. Gas bottles: Limited to one “refillable” gas bottle, per visit.
A standard charge of £5 per unit (i.e. up to 2 tyres or one bag of asbestos or one gas bottle) is proposed, to be increased in line with future increases in disposal costs and administration. b) The amount of construction waste to be brought into a HWRC by any single vehicle, or combined vehicle and trailer, is to be set at a maximum of one car boot load of construction waste. This would be equivalent to 3 bags, of up to 30kg weight per bag, this being a bag weight that the average person can lift. The waste is to comprise spoil, hardcore, soil, rubble, or equivalent. For larger items such as baths, the material would not need to be bagged, but should not exceed approx. 90kg in total or one average car boot load per visit. c) All commercial vehicles including pick-up trucks, vans, agricultural vehicles including horse boxes are to be excluded from HWRCs.
An exception scheme for householders with disabilities using over- height vehicles is to be introduced.
A permit scheme for the small number of householders who do not own any other vehicle, other than an excluded vehicle, and those with large private vehicles is provided. All other conditions, such as the limit on construction waste, will continue to apply. Permits will provide access to the sites on up to 12 occasions per calendar year. Any additional applications for permits in one year from the same household will be subject to investigation to ensure the exclusion of trade waste. d) Access to HWRCs for trailers is limited to those of up to 1.0m3 capacity. The total combined quantity of construction waste is to be limited as set out above. (The quantity is not to be doubled for a combined vehicle and trailer.) e) Support the development of additional commercial capacity where there is evidence of under-provision of waste disposal for businesses. Carry out a feasibility study on the opportunities at Kent County Council waste sites to promote cost-effective waste disposal capacity for businesses in order to ensure there are alternatives to fly-tipping. f) Provide close monitoring of fly-tipping across Kent to identify any hot- spots arising from the implementation of operational policy or network changes. Ensure prompt action and support to investigate offences and arrange for the removal of waste by working with the waste collection authorities. Launch a new media campaign based on zero-tolerance of fly-tipping and promoting responsible waste disposal. g) A comprehensive communications plan and information programme to be provided to support implementation of the operational changes.
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h) The existing permit scheme at Dartford Heath HWRC for Kent only residents is retained. A similar trial permit scheme is considered in 2013/14, at Swanley HWRC.
It is further recommended that the Corporate Director for Enterprise and Environment to implement the decision in respect of policy changes through a phased approach to ensure sufficient capacity to manage a smooth transition and to keep progress under continuous review to maximise customer service.
9.2 It is further recommended that the following changes are introduced in respect of the HWRC sites network:-
i) Carry out a site search in respect of the North West Kent and Mid Kent areas.
j) Close Richborough waste site in autumn 2013 at the end of the current contract term and Hawkinge waste site in autumn 2013 when the new Ashford Transfer station and improved household waste recycling centre is fully operational.
k) Review the HWRC provision in the Swale area subject to a further member decision when the replacement site for Church Marshes TS/HWRC is established.
10. Background documents:
Public Consultation Report – Household Waste Recycling Centres (February 2012) Equalities Impact Assessments (May 2011 – February 2012)
11. Author contact details Caroline Arnold, Head of Waste Management [email protected] 01622 605986
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Page 30 Appendix C
Kent County Council Waste Management
HOUSEHOLD WASTE RECYCLING CENTRES
PUBLIC CONSULTATION REPORT
April 2012
To be published online at: www.kent.gov.uk/hwrcconsultation
Household Waste Recycling Centres Public ConsultatiPageon Report31 Page 1 of 46 EXECUTIVE SUMMARY
Public Consultation: A ten week public consultation on proposed changes to the Household Waste Recycling Centre service in Kent was run from 1st December 2011 to 9th February 2012.
A full Equalities Impact Assessment (EIA) was conducted prior to the development and delivery of the public consultation and reviewed once the consultation had been completed.
The EIA shaped the engagement and participation mechanisms, identifying protected characteristics which had the potential to be negatively or positively impacted by the proposed policies, as well as ensuring that particular attention was paid to engagement with minority groups in Kent.
The consultation consisted of a questionnaire, available in both electronic and paper formats. Kent residents were invited to respond to the consultation using various communication methods, developed following Mosaic analysis, to ensure a broad range of target audiences were engaged with in a proportionate manner.
The communication methods used included: x Direct Mail x Engagement at HWRCs x Press advertisements x Posters in sports clubs/ societies x Gateways x KCC community engagement officers x Libraries x Key stakeholders x KCC website x Member briefing
Information was also sent to over 150 equalities groups across the county to inform them of the consultation and for wider circulation to members of their groups / communities.
A total of 3,499 consultation responses were received, consisting of: x 1,400 customer paper questionnaire responses; x 2,056 customer online responses; and
Household Waste Recycling Centres Public ConsultatiPageon Report 32 Page 2 of 46 x 43 stakeholder responses - received from district councils, parish councils, waste management contractors and other agencies.
Table 1 on the following page provides a summary of all responses received, aligned to each of the questions related to proposed operational and infrastructure changes asked within the consultation.
Decision:
Following the public consultation, recommendations were presented to Cabinet on 19th March 2012 for consideration which took into account the feedback obtained from the public consultation and the full EIA. You can view the Cabinet paper.
Cabinet endorsed all recommendations and delegated the final decision to the Cabinet Member for Environment, Highways and Waste.
A petition was received in respect of the proposal to close the Richborough HWRC. This was debated at the meeting of the County Council on Thursday 29th March 2012.
The Cabinet Member made his decision on 3rd April 2012 and a full copy of this can be found on our website.
Operational policy changes at HWRCs will be implemented during the summer of 2012, with extensive engagement to inform and support customers.
Household Waste Recycling Centres Public ConsultatiPageon Report33 Page 3 of 46 Table 1: Summary of all public consultation responses received CONSULTATION QUESTION OVERARCHING CUSTOMER RESPONSE OVERARCHING STAKEHOLDER RESPONSE PROPOSED OPERATIONAL POLICY CHANGES Q7. Do you consider that items such as x 60% of respondents agreed that items such as tyres, asbestos and gas bottles, which x 1 tyre / bottle per visit for free tyres, asbestos and gas bottles, which are are mainly commercial waste, should be excluded from HWRCs. x Charge for these materials if it means the facilities are HWRCS can remain mainly commercial waste, should be x 32% responded ‘no’. x Increase in flytipping would result excluded from Household Waste Recycling Comments included: x Where would householders take these items? Alternative disposal points need to be well promoted Centres, provided other disposal routes are x Potential flytipping of materials x Section 51 EPA – legal duty to accept materials for disposal available? x A perception that these materials are generated by householders and they have a need x Financial impact upon householder for cost of disposal for HWRCs to accept them x Increased cost to districts for removal of fly tipped waste or materials presented kerbside for collection, x Customers want a 1-stop shop for all materials and convenience of service therefore, no overall saving to public purse x Lack of information about alternative disposal points x It is reasonable to expect these items to come from the householder x Risk of hazardous waste being disposed of inappropriately x Policy is not in line with Vision for Kent or Kent Environment Strategy x Increased cost to councils for removal of flytipping x Policy ignores inherent value in waste that could be gained by charging for trade waste disposal x Hazardous nature of materials – environmental risks and costs associated with fly tipping materials x Impact assessment required x Gas cylinders are likely to be empty upon disposal x Gas bottles can be taken back and exchanged, therefore, no need to accept them Q8. Would you support the exclusion of x 67% of respondents would support the exclusion of trade waste e.g. by ceasing to open x Prevent legitimate customers from entering the HWRCs e.g. van hire by householders trade waste e.g. by ceasing to open the the height barrier and excluding trade vehicles. 25% of respondents would not. x Do not support determining legitimate disposal by vehicle type preferred by residents height barrier and excluding trade vehicles, Risks identified included: x Clear and accessible communication will be needed to residents which the Household Waste Recycling x Potentially increased flytipping x Should explore potential for income from trade waste Centres have no duty to accept and costs x What about householders who hire vans to transport household waste or who only have x Increase in fly tipping and cost to district councils the Council money? use of a van? x Open height barrier at weekend only x Instead, allow HWRCs to accept all waste from anyone - to save cost of flytipping x High level of 4x4 vehicles in Sevenoaks area – will not be able to access site removal and gain income from materials x 1 district and 3 parish councils support proposal x Council should encourage all waste to be disposed / recycled responsibly x Increased cost to districts for removal of fly tipped waste or materials presented kerbside for collection, x Implement charging scheme for traders at HWRCs instead? therefore, no overall saving to public purse Page 34 x Support the policy if this limits waste from non-domestic sources x Restricts ability of residents to move large waste items around for disposal easily x Policy does not support recycling behaviours x The type of vehicle should be irrelevant, access should be determined by source of waste x Suggest access for single axle domestic trailers x Domestic vehicles should be permitted Q9. Would you support the exclusion of x 65% of respondents would support the exclusion of construction waste at HWRCs. x Confusion over what is meant by ‘construction waste’ – municipal or commercial? construction waste, which the Household x 26% of respondents would not. x Increased cost to districts for removal of fly tipped waste or materials presented kerbside for collection, Waste Recycling Centres have no duty to Comments included: therefore, no overall saving to public purse accept and costs the Council money? x Potential increase in flytipping x Restriction on quantity will increase journeys made by householders – increase carbon emissions x Concern over penalising the DIYer, should be a provision to dispose of x Policy is not in line with Vision for Kent or Kent Environment Strategy x Charge for ALL construction waste regardless of its source? x The quantity limit is too low x Lack of information about alternative disposal points x Loss of valuable commodity x Need for robust enforcement strategy and costly to enforce at HWRCs Q10. Do you believe that councils should x 90% of respondents believe that councils should increase income by maximising the increase income by maximising the diversion of household waste for recycling. diversion of household waste for recycling? Q11. Do you believe it is reasonable for x 59% of respondents believe it is reasonable for householders who do not live in Kent to x This is as long as it is short householders who do not live in Kent, and be excluded from using Kent’s Household Waste Recycling Centres. x Does this include the relationship with Medway therefore do not contribute to the funding of x 34% of respondents do not believe it would be reasonable. x Negative impact on residents purse – funding of longer journeys sites, to be excluded from using Kent’s Comments included: x Does not encourage recycling Household Waste Recycling Centres? x Risks were identified including: x Duty to co-operate with neighbouring councils x Reciprocal arrangement with neighbouring councils is required; balance across border; x Difficult to police the policy petty proposal x Costly to introduce the policy x Increase in flytipping x Greater carbon impact from increased journey times x Convenience to use nearest HWRC regardless of borders x Environmental impact from increased distance to sites x Should be encouraging recycling not deterring x Boundaries shouldn't matter to customer services Q12. Do you use Household Waste x 8% of respondents use HWRCs in other areas. Recycling Centres in other areas? x Of those that do use HWRCs in other areas, 57% use Medway sites.
Household Waste Recycling Centres Public Consultation Report Page 4 of 46 CONSULTATION QUESTION OVERARCHING CUSTOMER RESPONSE OVERARCHING STAKEHOLDER RESPONSE PROPOSED INFRASTRUCTURE CHANGES Q13. Thinking of the Council’s aim to x 90% of respondents believe that the HWRCs are generally fit for purpose. continuously improve sites, do you believe that the Household Waste Recycling Key criticisms of the centres included: Centres are generally fit for purpose? x HWRC too small and poorly designed x Negative experience of queues to access HWRC and congestion x Need to increase material streams x Site staff - unhelpful and too many Q14. To help shape the future network of x Most respondents identified the range of materials accepted on site as one of the most Household Waste Recycling Centres, important factors of HWRCs. please tell us which of the following are the x Short journey times, short queues at the site, helpfulness of site staff and ease of three most important to you. access around the site as important. x Many respondents specified a desire for a reuse facility on site and longer opening hours. Q15. Would you support an overall x 30% of respondents would support an overall reduction in one or two sites across Kent, x Ensure sufficient capacity at sites – footfall and tonnages reduction in one or two sites across Kent, provided the service continued to be operated to a good standard across the remainder x Reducing number of HWRCs is not conducive to reducing waste to landfill provided the service continued to be of HWRCs. x A 20 minute drive time guideline is supported operated to a good standard across the x 55% of respondents would not support an overall reduction. remainder of Household Waste Recycling Centres? Comments included: x Increase in flytipping x Convenience to use nearest HWRC regardless of borders x Increased travel time / cost. x Environmental impact from increased distance to sites x Should be encouraging recycling not deterring x Boundaries shouldn't matter to customer services
Page 35 Q16. Taking into account proposals to x 36% of all respondents believed it is reasonable to close the site at Hawkinge. x Shepway DC support – provided no additional cost is incurred by the district, but does ask KCC to improve the facility at Ashford, do you x 46% of respondents answered they ‘did not know’ – after excluding these responses, seriously consider believe it is reasonable to close the out of 67% of the remaining respondents believed it is reasonable to close the site at x Closure not supported by local parish and town councils date and expensive to operate site at Hawkinge. x Increase in travel time and associated journey cost and emissions; risk of flytipping Hawkinge, provided services exist within a x Further analysis reveals that of those respondents that use Hawkinge HWRC, 92% x Support reduced number of materials accepted to reduce operating costs 20 minute drive time of your home? believe it should not be closed. x Misleading question and unsubstantiated statement – “out of data and expensive to operate” x Ambiguous question – transfer station or HWRC for closure? The main reasons that people answered ‘no’ to closing Hawkinge HWRC are: x Concerns about impact on Whitfield and Folkestone HWRCs x Journey times will be increased x Hawkinge should be improved/ updated x Increase in flytipping x Increase in fuel cost to residents and pollution from increased journeys x Hawkinge is a growing town/ area and needs it’s own HWRC x Some respondents state that the question is loaded and misleading x Some state that Ashford HWRC is more than 20 minutes away/ too far to travel to Q17. Taking into account that there is a x 41% of all respondents believed it is reasonable to close the site at Richborough. x Additional journey time for residents to alternative HWRCs facility at Deal and at Margate, do you x 42% of respondents answered they ‘did not know’ – after excluding these responses, x Adverse traffic impacts on local road network around Deal and Whitfield – review and advantage taken believe it is reasonable to close the out of 72% of the remaining respondents believed it is reasonable to close the site at of Section 106 Town and Country Planning Act 1990 for highway improvements date and expensive to operate site at Richborough. x Several responses do not support the closure Richborough, provided services exist within x Further analysis reveals that of those respondents that use Richborough HWRC, 80% x Deal Transport and Flood Alleviation Study – infrastructure assessment a 20 minute drive time of your home? believe it should not be closed. x Margate HWRC necessitates a longer walk with heavy items x Please consider older people who would have further to drive The main reasons that people answered ‘no’ to closing Richborough HWRC are: x Increase in flytipping x Journey times will be increased – 20 minutes is too far x How is the site out of data? x The road infrastructure does not make the alternative HWRCs easily accessible x Location provides a service to southern half of the Thanet district x Increase in flytipping x The HWRC is always busy and shouldn't be closed x A few respondents commented that Richborough HWRC should stay because the Thanet Waste is being expanded. Q18. The Household Waste Recycling x 50% of respondents believe that the Household Waste Recycling Centres at Dartford x Dartford Borough Council supported this proposal. Centres at Dartford Heath and Swanley Heath and Swanley should be replaced with modern facilities. currently operate at full capacity with no x Further analysis reveals that of those respondents that use Dartford Heath and Swanley scope for expansion. Do you agree they HWRC, 47% believe they should be replaced with modern facilities. should be replaced with modern facilities?
Household Waste Recycling Centres Public Consultation Report Page 5 of 46 CONSULTATION QUESTION OVERARCHING CUSTOMER RESPONSE OVERARCHING STAKEHOLDER RESPONSE The main reasons that people answered ‘no’ to replacing Dartford Heath and Swanley with more modern facilities are: x Respondents believe that the sites are fine as they are x Respondents are concerned that updating them would mean moving them to one site rather than two separate sites x Some respondents feel that there is not enough information provided to make judgement e.g. what is meant by ‘modern facilities?’ x Dartford Borough Council supported this proposal. Q19. Do you agree that the Household x 24% of respondents believe that the HWRC at Church Marshes should be replaced with x Maidstone BC support relocation of HWRC and Transfer station to reduce congestion and access are Waste Recycling Centre at Church a new facility in a more accessible location. improved Marshes, Sittingbourne, is inadequate and x Further analysis reveals that of those respondents that use Church Marshes HWRC, x May deter flytipping should be replaced with a new facility at a just 40% believe it should be replaced with a new facility. x Would reduce vehicle emissions more accessible location, to provide a more x Care to identify location which doesn’t impact environmentally sensitive land efficient service to Swale residents? Comments included: x Respondents are happy with Church Marshes as it is x Many respondents are concerned that this will result in the closure of Sheerness/ Faversham HWRC x Some respondents feel there is not enough information provided on where the new site would be Q20. Do you support the provision of an x 52% of respondents support the provision of an additional HWRC in the Tonbridge and x Widespread from organisations for a HWRC in the area additional Household Waste Recycling Malling area. x Improving access to existing sites should be considered before building new HWRCs Centre in the Tonbridge and Malling area, x Recognised over-crowding at some existing sites e.g. Tovil which is currently not covered by the x High level of illegal waste sites in mid Kent existing network? x EA support for HWRC development in Staplehurst / Headcorn area x “Additional sites should be considered on journey time and not differentiated by district boundaries” x “It is no coincidence that the mid Kent area, where there is no HWRC, has the highest number of illegal waste sites”
Page 36 Q21. Do you support the upgrading of the x 50% of respondents would support an upgrading of the existing HWRC at Ashford. x Stakeholders demonstrated support for upgrading of HWRC and provision of new transfer station existing Household Waste Recycling Centre x Further analysis reveals that of those respondents that use Ashford HWRC, 88% at Ashford, which forms part of the proposal support the upgrading of the site. for a new waste transfer station (which bulks household waste for haulage to reprocessors)? Q22. If you do not use a Kent Household The main suggested improvements include: Waste Recycling Centre, are there any x Many want on-site shops to buy things that are still in good condition improvements that would encourage you x Many want to be able to recycle more things ESPECIALLY PLASTICS to? x A facility closer to home/ more sites x Allow over height vehicles x More helpful staff x More help with carrying heavy items x Better/ more parking on site x Mobile collections from home for elderly and people without a car x Increase the opening hours x Improve the ease of access x No steps Many commented that there wasn't the opportunity in the questionnaire to suggest improvements for those that already use the HWRCs
Household Waste Recycling Centres Public Consultation Report Page 6 of 46 CONTENTS
Page ii) Executive summary 2 ii) Contents 7
1. Introduction: Decision making process 8
2. Background 9
2. Consultation Process 11
3. Equalities Impact Assessment 18
5. Respondent profile and activity 22
6. Operational policy changes: consultation responses 25
7. Infrastructure investment: consultation responses 31
8. Current service provision: consultation responses 42
9. Consultation responses: “about you” 44
10. Post consultation 46
Page 37 Household Waste Recycling Centres Public Consultation Report Page 7 of 46 1. INTRODUCTION: DECISION MAKING PROCESS
An Informal Members Group was established in April 2011 with the purpose of undertaking a review of Household Waste Recycling Centre (HWRC) provision in Kent to identify the right level of HWRC service for Kent residents at the right cost.
Terms of reference for the Informal Members Group (IMG) were agreed by the Policy Overview and Scrutiny Committee (POSC) for Environment, Highways and Waste at its meeting on 8th April 2011.
The IMG met 3 times, plus a tour on 27 July of some of the Household Waste Recycling Centres. In particular, the tour took account of the extent of perceived trade waste entering Household Waste Recycling Centres and the existing network infrastructure.
The review produced a report outlining the issues and giving a series of recommendations on how the HWRC service could change to deliver the optimum service for the customer and financially. The report from the IMG was considered by the POSC for Environment, Highways and Waste on 27th September 2011 prior to the proposed policies being presented to the Cabinet Member for Environment Highways and Waste. An Equality Impact Assessment was conducted to accompany the proposals.
These proposals were subject to a ten week public consultation from 1st December 2011 to 9th February 2012. The responses were reviewed to inform a further Equality Impact Assessment.
This report presents the responses received to the public consultation and was presented to Cabinet by Bryan Sweetland, Cabinet Member for Environment Highways and Waste, on 19th March 2012. This report also outlines the ultimate decision made by the Cabinet Member.
Page 38 Household Waste Recycling Centres Public Consultation Report Page 8 of 46 2. BACKGROUND
2.1 CURRENT SERVICE PROVISION Kent County Council is the statutory Waste Disposal Authority (WDA) for the county. There has been a duty on the WDA to provide Household Waste Recycling Centres (HWRCs) originally going back as far as the Civic Amenity Act 1967. The duty is now embodied within section 51 of the Environmental Protection act 1990. In summary, the act states that HWRCs must be provided free of charge and open over part of a weekend. The Act also includes a power to charge for waste other than household waste at Household Waste Recycling Centres.
As a result of this duty and associated powers, the household waste network has evolved over many years to its current level of network infrastructure provision, operating policy, and management arrangements.
There are currently 19 HWRCs provided across Kent, largely located close to each significant urban area in Kent. In most cases there is one HWRC per district area, some districts (Sevenoaks, Canterbury, Thanet, and Dover) have two, and in two cases (Swale and Shepway) each have three HWRCs. Tonbridge & Malling BC has no HWRC within its administrative area, but as a significant number of TMBC residents use Medway sites, KCC makes a financial contribution to Medway Council to compensate them for this cross-border activity.
Of these 19 HWRCs, 6 are co-located with waste transfer stations provided by KCC. The function of the transfer stations is to bulk up household waste collected by the waste collection authorities. Only the waste transfer stations have weighbridges and accept trade waste based on charges by tonnage.
The sites’ management is out-sourced and managed under contract by external contractors, with the exception of Church Marshes at Sittingbourne and New Romney which are both managed by Kent Commercial Services, part of Kent County Council.
Page 39 Household Waste Recycling Centres Public Consultation Report Page 9 of 46 2.2 CURRENT OPERATING POLICY KCC last reviewed its operating policy in January 2009 and the key points of the policy are: x Providing a height barrier of 2m to prevent access by large vehicles; x Prohibiting the practice of “walking-in” waste from over-height vehicles parked outside; x Opening the height barrier for householders only with large vehicles on Wednesdays and Saturdays only at selected larger sites; x Limiting the size of trailers; and x Continuing to provide a permit scheme for Kent residents at the Dartford Heath site.
2.3 CURRENT OPERATING COSTS The net cost associated with the operation of the HWRC service is made up of four basic elements:
i) The cost of operating and maintaining the sites, together with the costs of transporting the various separated materials for disposal or processing elsewhere (the current HWRC “contract costs”); ii) The cost of processing of the recyclables or compostable materials received at the sites; iii) The cost of disposing of the residual waste unable to be recycled received at the sites;
Offset in part by:
iv) The income received from the sale of those recyclable materials with a positive value.
Even where a recyclable material has no positive value, nowadays it generally costs less to recycle (or compost) than sending it for disposal. Increasing recycling reduces the overall cost of the HWRC service.
In some cases certain defined materials or items must be kept separate for recycling or specialist disposal, because environmental regulations do not permit them to be sent to landfill or incineration e.g. Waste Electrical Items (WEEE), waste oil, plasterboard, tyres, gas bottles. Some of these materials are collected from the sites free of charge by third party contractors - others attract haulage and processing costs.
Currently 26% of all household waste arisings in Kent is received and handled through the HWRC network. The other 74% is largely collected from the kerbside by the 12 district Page 40 Household Waste Recycling Centres Public Consultation Report Page 10 of 46 councils as the waste collection authorities with the remainder collected through recycling bring banks. The County Council has a duty to meet the cost of disposing of this district council collected waste. Further details are provided in table 2 below.
Table 2: 2010/11 waste arisings % of waste stream 2010/11 arisings KCC's waste arisings managed (tonnes) HWRC Managed Waste 26.3% 193,687 Waste Collection Authorities 69.8% 513,470 Kerbside Collections Bring Site 3.2% 23,553 3rd Party Recycling Collections 0.7% 5,252 Total arisings 735,962
3. CONSULTATION PROCESS
The policies proposed in the consultation had the potential to affect every household in Kent. It was therefore important to devise engagement mechanisms to provide the opportunity for participation equally across Kent communities, being mindful of communication preferences and accessibility of information.
The consultation consisted of a questionnaire, available in both electronic and paper formats. Kent residents were made aware of the consultation and invited to respond using various communication methods to ensure a broad range of target audiences were engaged with in a proportionate manner.
The Equality Impact Assessment shaped the engagement and participation mechanisms, identifying protected characteristics which had the potential to be negatively impacted by the proposed policies, as well as ensuring that particular attention was paid to engagement with minority groups in Kent.
3.1 MOSAIC ANALYSIS Mosaic, a customer segmentation tool, was used to understand the best way to engage with the residents in Kent. Within Kent, a bespoke Mosaic segmentation has been created using county specific data, whereby every postcode and household in Kent is classified as belonging to one of 69 types and 15 groups. These groups identify clusters of individuals and
Page 41 Household Waste Recycling Centres Public Consultation Report Page 11 of 46 households that are as similar as possible to each other, and as different as possible to any other group. Mosaic was used in this instance to understand communication preferences to ensure that residents in Kent were informed about the consultation in a way that they are more likely to be receptive to.
In preparation for the consultation, a sample of postcodes for HWRC users were collated and profiled, to understand the make-up of the current customer base and their communication preferences. The profile of HWRC users was compared with the Mosaic profile of the Kent population as a whole, in order to understand those people more or less likely to use an HWRC user. This supported the development of targeted communication across all Mosaic groups to ensure a representative sample of Kent residents were engaged with.
The following communication approaches were developed and delivered based on Mosaic Analysis:
3.1.1. Direct Mail Mosaic was used to identify those residents in Kent more likely to be receptive to direct mail as a communication method. In order to determine the content of the direct mail, likely use of the Internet was also established (i.e. promoting a website would be inappropriate if Internet use was low).
As a result, a paper copy of the consultation questionnaire was sent to a random sample of residents belonging to Mosaic groups which were likely to be responsive to direct mail but less likely to have access to the internet. Residents were informed on the covering letter that their address had been selected at random and asked them to encourage others to respond also.
A second direct mail which took the form of a postcard with key points about the consultation and how to participate was sent to a sample of Kent households which were likely to be receptive to direct mail, but also likely to have access to the internet. The postcard signposted residents to the online consultation questionnaire whilst also giving them the option to request a paper copy (or alternative formats) if they preferred.
In light of the questionnaire proposing the closure of Hawkinge and Richborough HWRCs, the direct mail was up-weighted in the areas near these two sites.
Page 42 Household Waste Recycling Centres Public Consultation Report Page 12 of 46 3.1.2. Sports clubs/ societies Mosaic variables were used to understand which sports/ activities specific groups are likely to be interested in. As a result, posters were sent to sports clubs/ societies in Kent in specific areas based on the characteristics of the population in that area. For example, posters were sent to bowls clubs and golf clubs in area in Kent were there is known to be an older population and posters were sent to gyms where the communities are more likely to undertake this kind of activity.
3.2 OTHER COMMUNICATION APPROACHES
3.2.1. KCC website A dedicated web page (www.kent.gov.uk/hwrcconsultation) was created on the KCC website to provide consultation information and access to the online questionnaire. An email address was also created specifically for any email correspondence ([email protected]) during the consultation period.
3.2.2. Gateways Each of the 9 Kent Gateways were provided with a supply of postcards, posters and paper copies of the consultation questionnaire, in order to give Kent residents another route with which to obtain a questionnaire should they be Gateway users. Gateways with ‘information screens’ carried information about the consultation.
3.2.3. Libraries A poster advertising the consultation along with a number of postcards and paper copies of the questionnaire were provided to each of the 99 KCC Libraries and 11 KCC Mobile Libraries.
3.2.4. Engagement at HWRCs Whilst it remained important to ensure that those residents that do not currently use the HWRCs are made aware of the consultation, providing information at the sites themselves direct to service users was very important. A sign advertising the consultation was installed at each of the 19 HWRCs on the 1st or 2nd of December 2011 and displayed for the full 10 weeks.
Page 43 Household Waste Recycling Centres Public Consultation Report Page 13 of 46 Furthermore, between 1st December and 4th December 2011, KCC Waste Management officers successfully handed 5,500 postcards to HWRC customers promoting the consultation across all 19 HWRCs. These were handed out during the weekdays and weekend to ensure that different audiences were engaged with and at the earliest opportunity within the consultation period.
3.2.5. Press advertisements Mosaic was able to provide an indication of which areas in Kent would be receptive to press advertisements as a communication method. However, it was felt that it would be more reasonable to run county-wide advertising to achieve the greatest reach, equality of access and achieve greatest value for money. In the week commencing 28th November 2011, a press advertisement was placed in all Kent Messenger paid for titles in Kent, as well as Thanet Extra, Sittingbourne Extra and Messenger Extras (formerly Gravesend, Dartford & Swanley Extra) which are free titles (as no dominant paid for title exists in these areas). A press advertisement was also placed in the Tunbridge Wells Courier and Tonbridge Courier.
3.2.6. KCC community engagement officers All 12 KCC Community Engagement Officers were provided with information prior the launch of the consultation to provide them with information should any members of their communities raise the subject at meetings or make an enquiry.
3.2.7. Key stakeholders As well as communicating with individual residents of Kent, key stakeholders were also engaged with to encourage them to contribute to the consultation process. The following stakeholders were engaged with: x All Kent parish and town councils were sent a paper copy of the questionnaire for the 1st December 2011 and were asked to make their residents aware of the consultation. Feedback was encouraged as individuals or as a combined response of the whole parish. Included within this was the Kent Association of Local Councils. x Waste Managers from all 12 Kent district councils and Medway Council were provided with a paper and electronic copy of the questionnaire and encouraged to respond to proposals via email. x The Environment Agency was provided with a paper copy of the questionnaire and encouraged to respond to proposals via email. x A paper copy of the questionnaire was also sent to KCC waste contractors. x Kent Fire and Rescue Service were also approached. Page 44 Household Waste Recycling Centres Public Consultation Report Page 14 of 46 3.2.8. Member briefing A Member briefing was held on 1st November 2011 at which Cabinet Member for Environment Highways and Waste Bryan Sweetland introduced the proposed policies and facilitated a discussion. A total of 22 Members attended this with a further 24 sending their apologies. This included Members from the Conservative, Liberal Democrats and Independent parties with a good geographical spread covering all 12 district council areas. In addition, a briefing document was provided to all KCC Members from Bryan Sweetland on the 30th November 2011.
3.3 EQUALITY CONSIDERATIONS
3.3.1 Equality groups Kent County Council is committed to ensuring that current and potential service users will not be discriminated against on the grounds of their social circumstances or background, such as gender, race, colour, ethnic origin, religion or belief, disability, gender identity, sexual orientation or age. As a result, a letter and / or e-mail was sent to over 150 equalities groups across the county to inform them of the consultation and to ask them to circulate the information to members of their groups / communities. These groups were informed that responses were welcome from individuals or as a group/ organisation. The following groups were contacted: x Age groups, including all age forums in Kent x BME groups x Disability groups x Gender groups x Refugee groups x Religion groups x Sexuality groups.
Furthermore, consultation questionnaires were provided to influential members of the Gypsy and Irish Traveller communities to disseminate amongst their communities as it was felt that these had not been represented elsewhere.
Page 45 Household Waste Recycling Centres Public Consultation Report Page 15 of 46 3.3.2 Alternative formats Prior to the launch of the consultation, the consultation questionnaire was produced in alternative formats: x Easy Read; x Large Print; x Audio format; and x Braille. Alterative language formats would have been accommodated if required, however, no requests were received.
3.4. SCALE OF CONSULTATION ENGAGEMENT Table 3 below identifies the distribution of each of the communication methods along with an estimate of the potential reach achieved. The ‘reach’ provides an indicative – rather than exact - figure of the number of households in Kent directly communicated with. For example, the newspaper titles alone which included the press advertisement could be read by approximately 34% of households in Kent.
COMMUNICATION REACH METHOD Measurable reach figures Direct mail – paper 2,848 households questionnaire This includes an up-weighting in Richborough and Hawkinge Direct mail - postcards 8,153 households This includes an up-weighting in Richborough and Hawkinge Postcards – handed out at 5,500 unique visitors which is equal to approximately 8% of HWRCs all weekly users Press ads Readership – 493,375 people which equates to approximately 205,500 households Un-measurable reach figures Gateway – screens, Available in all 9 Kent Gateways postcards and paper copies Libraries – posters and Available in all 99 KCC Libraries and 11 mobile libraries postcards Sports clubs/ societies - Sent to 123 selected sports clubs poster Community centres - poster Sent to 7 community centres in the Sandwich, Ramsgate and Folkestone areas These were included to make the consultation more accessible to residents living near Richborough and Hawkinge Diversity groups – letter and/ Sent to 12 Older People’s Forum chairs Page 46 Household Waste Recycling Centres Public Consultation Report Page 16 of 46 or email Sent to 164 other diversity groups Email sent to the 4 KCC staff groups Community Engagement Email sent to the 12 KCC Community Engagement Officers Officers - email Stakeholders Parish and Town Councils – Sent to all 305 town and parish councils letter and paper copy District Council Waste Sent to 12 Kent district/ borough councils and Medway Managers – letter and paper Council copy Environment Agency – letter Sent to the Area Manager for Kent & East Sussex and paper copy KCC HWRC contractors – Sent to all 5 HWRC contractors letter and paper copy Kent Fire and Rescue Kent Fire and Rescue Service were approached Service
Page 47 Household Waste Recycling Centres Public Consultation Report Page 17 of 46 4. EQUALITIES IMPACT ASSESSMENT
KCC is committed to providing the best level of HWRC service to all its customers. To ensure this happens we need to take robust and relevant assessment of the likely impact of our work on the diverse communities and individuals who live in Kent. The Equality Impact Assessment (EIA), aside from being a legal duty for public bodies to complete, also provides a process to help us to understand how the proposed HWRC policies and service changes may affect Kent residents from all communities. The EIA will help to ensure that KCC is providing an inclusive HWRC service.
An EIA was completed prior to commencing the consultation, which shaped the engagement and participation mechanisms, to provide the opportunity for participation equally across Kent communities and being mindful of communication preferences and accessibility of information.
The EIA was reviewed after the consultation to enable KCC to respond to any new issues that arose during the consultation and to ensure no groups were disadvantaged.
Table 4 (page 19) is an action plan in response to impacts identified for the protected characteristics (e.g. age, disability) which is to be implemented in response to policy changes.
You can view the full EIA.
Page 48 Household Waste Recycling Centres Public Consultation Report Page 18 of 46 Table 4: EIA Action plan Protected Issues identified Action to be taken Expected outcomes Owner Timescale / Characteristic Cost implications Change in Communicate the outcome of the Outcome of HWRC Review Head of operational HWRC review and public consultation to older made available to older people. Waste April / May 2012 policies following a residents. Management AGE Cabinet decision. Develop and deliver an implementation Implementation prepared and plan for introduction of new operational budget secured. policies, which provides for engagement with older customers. Possible increase in Provide comprehensive, targeted and Older people receptive to From June 2012 journey distance and timely communication to older people to communications delivered. time for some support awareness of alternative residents who have HWRCs available to them in their Older residents able to dispose been using locality. of their waste appropriately. Hawkinge1 and Page 49 Richborough HWRCs Ensure information about all council Older people aware of to date. waste services is accessible to older alternative HWRCs and able to people to provide them with choice for locate them easily. their waste disposal needs. Decrease in journey Advertising of new HWRC during build Older people aware of new Subject to capital time for residents in phase to inform potential service users HWRC, the nature of the service programme Tonbridge and of new facility. and the location. Malling and north Maidstone areas with Promotion of the opening of the new additional HWRC HWRC to older people within the provided. ‘catchment’ area. Ensure older people Ensure preferred communication Communication of key To support all are communicated channels are utilised to communicate information is received by older delivery. with appropriately to with these target audiences, drawing on people with ease. In accordance to meet their needs and Mosaic information and local data. the capital ensure messages programme and are conveyed existing site appropriately. improvement plans.
1 Remains within 20 minute drive time, equitable for residents elsewhere in east Kent. Household Waste Recycling Centres Public Consultation Report Page 19 of 46 Protected Issues identified Action to be taken Expected outcomes Owner Timescale / Characteristic Cost implications Change in Communicate the outcome of the Outcome of HWRC Review Head of April / May 2012 operational HWRC review and public consultation to made available to residents with Waste policies following a organisations representing disability. disabilities through Management Cabinet decision. representative organisations / DISABILITY Develop and deliver an implementation groups in Kent. plan for introduction of new operational policies, which provides for engagement Implementation prepared and with customers who have disabilities. budget secured. Cabinet approval for Ensure accessibility for customers with Improved accessibility for HWRC network disabilities is fully considered at design customers with disabilities. Head of To support all infrastructure stage for new HWRCs and for site Waste delivery. development and improvements at existing HWRCs. Management In accordance to improvements will Engage with disability groups within the capital enable accessibility Kent to help inform new site design or programme and to be enhanced. improvements. existing site Page 50 improvement Communicate site improvements / plans. design to communities representing disability. Accessibility to site Develop procedure to ensure customers Equitable access for customers Procedures for customers with with over-height adapted vehicles are with disability vehicles requiring developed April over-height adapted able to access HWRCs at their entry to HWRCs. 2012 vehicles. convenience and for KCC to Customer communicate this appropriately to engagement relevant customers. from May 2012 Possible increase in Provide comprehensive, targeted and Residents with disabilities able From June 2012 journey distance and timely communication to disability to dispose of their waste time to HWRCs, for groups / organisations in Kent Or appropriately. some residents who individuals upon request), to support have been using awareness of alternative HWRCs Residents with disabilities aware Hawkinge and available in the locality. of alternative HWRCs and able Richborough HWRCs to locate them easily. to date. Distribute information about all council waste services to disability groups / organisations in Kent, so that people have choices as to how to dispose of their household waste.
Household Waste Recycling Centres Public Consultation Report Page 20 of 46 Protected Issues identified Action to be taken Expected outcomes Owner Timescale / Characteristic Cost implications Change in Ensure that the outcome of the HWRC Outcome of HWRC Review Head of operational HWRC Review and public consultation is made made available to organisations Waste April / May 2012 policies following a available in alternative languages and / groups representing ethnic Management Cabinet decision. appropriate formats for ethnically groups in Kent. RACE diverse residents of Kent. Implementation prepared and Develop and deliver an implementation budget secured. plan for introduction of new operational policies which provides for engagement with ethnically diverse customers.
Change in Communicate the outcome of the Outcome of HWRC Review Head of April / May 2012 operational HWRC review and public consultation. made available. Waste PREGNANCY policies following a Management AND Cabinet decision. Develop and deliver an implementation Implementation prepared and
Page 51 MATERNITY plan for introduction of new operational budget secured. policies – with regard to this protected characteristic HWRC site staff will continue to provide pregnant women with assistance for carrying and lifting waste materials, and ensuring children remain in vehicles for safety. Ensure that this is communicated sensitively in customer information.
Possible increase in Provide timely communication to Pregnant women and / or those From June 2012 journey distance and support awareness of alternative with young children are able to time for some HWRCs available in the locality. dispose of their waste residents who have appropriately. been using Hawkinge Ensure information about all council and Richborough waste services is accessible to Parents aware of alternative HWRCs to date. residents to provide them with choice HWRCs and able to locate them for their waste disposal needs. easily.
Household Waste Recycling Centres Public Consultation Report Page 21 of 46 5. RESPONDENT PROFILE AND ACTIVITY
5.1 NUMBER OF RESPONSES RECEIVED
Total responses received: 3,499 ¾ Customer responses: 3,456 consisting of: x 1,400 paper responses; and x 2,056 online responses. ¾ Stakeholder responses: 43 stakeholder responses were received from district councils, parish councils, waste management contractors and other agencies.
Of these responses, 2 respondents requested large print versions of the consultation questionnaire. 4 responses, one of which being Easy Read, were received over the telephone and entered directly online by KCC officers.
As an example comparator, a recent Minerals & Waste consultation for the ‘Core Strategy and Minerals and Waste options’ received around 3,500 responses, some which were from the same individuals. A subsequent ‘supplementary options’ consultation received 362 responses from 213 individuals.
5.2 RESPONSE RATE AND METHOD Table 5 below details the responses received via the various methods of response submission, with response rates where calculation has been possible.
Number of Response Response submission method responses received rate Total completed paper questionnaires received 1,400 45% Total online questionnaires submitted 2,056 N/A District Council responses received 8/13 62% Town/ Parish Councils responses received 28/305 9% Environment Agency response received 1/1 100% HWRC Contractor responses received 2/5 40% Table 6: Responses received according to submission method
The high response rate of 45% for the paper questionnaire is attributable to the targeted direct mail using Mosaic data. All online respondents were additionally asked ‘how did you hear about the public consultation’? Graph 1 below presents the responses to this question. Please
Page 52 Household Waste Recycling Centres Public Consultation Report Page 22 of 46 note, respondents were able to choose more than one communication method, therefore the percentage has been calculated from all answers rather than the number of respondents.
Graph 1: How those respondents who completed the questionnaire online heard about the consultation.
I received a letter through the post
7% I received a postcard through the 17% post I received a postcard when I visited a 15% KCC HWRC I picked up a postcard at a KCC Gateway I picked up a postcard at a KCC 8% Library I saw a poster
I saw a sign when I visited a KCC HWRC 12% 18% I saw an advert in a newspaper I heard about it through a local community group 1% I heard about it through friends or 3% 14% family 4% Other 1%
17% of respondents commented that they had heard about the consultation through ‘other’ means. These ‘other’ responses can be found in table 7 below.
Number of Number of respondents respondents Parish Council 74 I am a councillor 5 Told about whilst visiting Website (unspecified) 55 HWRC 4 Email 43 Email through work 4 KCC Website 39 Community Warden 3 Local council website 15 Radio 3 Watch (eWatch + Neighbourhood Watch) 11 News 3 Local newsletter/online publication 8 Knet 1 BBC Website 7 Petition in shop 1 Email through work at LA 7 In response to my letter 1 Facebook 6 Ceefax 1 Email from Staff group 5 Can't remember 1 Twitter 5 Letter from work 1 Table 7: ‘Other’ response composition
Page 53 Household Waste Recycling Centres Public Consultation Report Page 23 of 46 5.3 CUSTOMER RESPONSE PROFILE Out of the total number of 98% provided their post code. Graphs 2 and 3 below represent the distribution of the recognisable post codes provided by 3,253 customer respondents (94%).
3% 0.3% Ashford 3% 4% Canterbury 16% Dartford 14% Dover Gravesham 4% Maidstone Sevenoaks 11% 7% Shepway 2% Swale Thanet 12% Tonbridge & Malling 18% 6% Tunbridge Wells Outside Kent
Graph 2: Geographical distribution of customer respondents, grouped by Kent district
Please note that out of the 3,390 postcodes provided, 137 were unrecognisable on the software used for this analysis. This distribution has been influenced by the diversity of communications distributed throughout Kent e.g. up weighted communications for the Hawkinge and Richborough areas
% of all responses % of Kent's adult population 20 18 16 14 12 10 8 Overall % 6 4 2 0
t r e le e s m rd n n ing k ve ay a bury to a ll oa w tfo r h a n Do sh r te ids Swa T M e ep n a Ashford ve Da & Sh ra Ca M e Sev G ridg b n Tunbridge Wells o T
Graph 3: Geographical distribution of customer responses - % of responses against % of Kent’s adult population.
Page 54 Household Waste Recycling Centres Public Consultation Report Page 24 of 46 5.4 STAKEHOLDER RESPONSE PROFILE A total of 43 responses were received from stakeholders including district and parish councils, waste management contractors and other agencies.
Table 6: Stakeholder respondents and date response received Respondent Respondent type Lydd Town Council Brasted PC Challock PC Doddington PC Preston & Elmstone Village Society The Ramsgate Society Shoreham PC Boxley PC Walmer PC Hothfield PC Faversham Town Council Preston PC Parish council Sevenoaks Districts Seniors Action Forum West Malling PC (28 responses) Swanley Town Council Stanford PC Bilsington Parish Council Swingfield Minnis Parish Council Kemsing PC Lynsted and Kingsdown PC Bredhurst Parish Council Sundridge With Ide Hill PC Hawkinge TC Sevenoaks TC The Kent Association of Local Councils (KALC) Cliffsend PC Southfleet Parish Council Vigo Parish Council Canterbury CC Thanet DC District Council Maidstone BC Gravesham BC (8 responses) Tonbridge and Malling BC Dover DC Dartford BC Shepway DC Other agencies Kent Fire and Rescue Service West Kent YMCA (4 responses) Environment Agency CPRE Kent WM contractor Roud Recycling Sita (3 responses) WRG
It should be noted that in addition to the engagement materials disseminated a Kent County Council Waste Manager, presented at a public meeting chaired by Hawkinge Town Council on 10th January 2012 in order to engage further with those concerned parties.
6 OPERATIONAL POLICY CHANGES: CONSULTATION RESPONSES
Please note: Customer responses (3456) have been used for the following analysis, with the stakeholder responses being identified separately and qualitatively. The responses to each question are considered one at a time. Not every question had to be answered by respondents and as a result the number of responses will not add up to 3,456 each time.
Page 55 Household Waste Recycling Centres Public Consultation Report Page 25 of 46 6.3 Do you consider that items such as tyres, asbestos and gas bottles, which are x Customer response summary: mainly commercial waste, should be excluded from Household Waste Recycling Total Most Number of Number of number popular Centres, provided other disposal routes are available? (Question 7) Theme of comments online paper of comments - comments comments comments ranked Materials will be flytipped 377 169 546 1 8% Believe these materials are generated by householders and they have a need for HWRCs to accept them 278 81 359 2 Customers want a 1-stop shop for all materials and convenience of service 106 32 138 3 Lack of information about alternative disposal points 87 36 123 4 Increased cost to councils for removal of flytipping 35 8 43 5 Yes 32% Risk of hazardous waste being disposed of inappropriately 24 19 43 5 No Allow HWRCs to accept all waste from anyone 2 1 3 Don't know Provide alternative sites for disposal 3 0 3 60% These materials increase tonnages and income for KCC 2 0 2 Traders should be excluded from HWRCs 7 4 11 Support ban of tyres but not asbestos or gas cylinders 7 1 8 Charge householders for these items or limit quantity 12 4 16 Charge traders, KCC gain income 13 4 17 Policy risks contamination of other waste streams e.g. residual 9 5 14 Exclude tyres and asbestos 4 3 7 Support exclusion of tyres and gas bottles 5 0 5 Page 56 x Stakeholder response summary: Object to any charges introduced or having to pay for a Key comments collection service 18 11 29 KCC should be encouraging people to recycle and make it x 1 tyre / bottle per visit for free easy 16 6 22 x Charge for these materials if it means the facilities are HWRCS can remain Policies are too restrictive and inconvenient 2 0 2 x Increase in flytipping would result Penalises the DIYer, home mechanic and associated x Where would householders take these items? Alternative disposal points would need to be well costs to householders 20 3 23 promoted No alternative options defined by KCC 4 2 6 x Section 51 EPA – legal duty to accept materials for disposal x Financial impact upon householder for cost of disposal Comments relating to SMEs wishing to use HWRCs 0 5 5 x Increased cost to districts for removal of fly tipped waste or materials presented kerbside for TOTAL 1031 394 1425 collection, therefore, no overall saving to public purse x It is reasonable to expect these items to come from the householder x Notable customer sound bites: x Policy is not in line with Vision for Kent or Kent Environment Strategy “There are times when householders won’t dispose of these items at their convenience and to take them to a x Policy ignores the inherent value in waste that could be gained by introducing charges for trade recycling site should be encouraged, as it reduces flytipping and prevents unregulated / unlicensed ‘man in truck’ waste disposal outfits from profiteering.” x Hazardous nature of materials – environmental risks and costs associated with fly tipping “I pay rates to dump as I please.” materials x Impact assessment required “I am mindful of the fact that this costs the council, and me as a council tax payer, money but on balance I am x Gas cylinders are likely to be empty upon disposal – low risk of explosion prepared to bear the cost.” x Gas bottles can be taken back and exchanged, therefore, no need to accept them Notable sound bites x Overarching summary: o 60% of respondents agreed that items such as tyres, asbestos and gas bottles, which are mainly x “Failure to accept or provide alternative means of disposal risks increased flytipping and costs to commercial waste, should be excluded from HWRCs, with 32% responding ‘no’. Waste Collection Authorities” o Risks identified included: x “Any savings made would be offset by the increased cost of clearing up the materials when fly Potential flytipping of materials tipped – false economy” A perception that these materials are generated by householders and they have a need for HWRCs to x “Would be a retrograde step” accept them x “Believe this to pose a larger negative impact on householders than businesses” Customers want a 1-stop shop for all materials and convenience of service Lack of information about alternative disposal points Risk of hazardous waste being disposed of inappropriately Increased cost to councils for removal of flytipping
Household Waste Recycling Centres Public Consultation Report Page 26 of 46 6.4 Would you support the exclusion of trade waste e.g. by ceasing to open the height barrier and excluding trade vehicles, which the Household Waste Recycling Centres have no duty to accept and costs the Council money? (Question 8) x Customer response summary: Total Most Number of Number of number popular Theme of comments online paper of comments 8% comments comments comments - ranked Increase in flytipping 287 39 326 1 Implement charging scheme for traders at HWRCs 96 27 123 2 What about householders who hire vans to transport 25% household waste or who only have use of a van 86 36 122 3 Yes Allow HWRCs to accept all waste from anyone - to save cost of flytipping removal and gain income from No materials 70 25 95 4 Don't know Council should encourage all waste to be disposed / recycled responsibly 38 13 51 5 Concern that trade and household waste cannot be 67% distinguished easily 4 1 5 The questions are biased 3 0 3 Accept trade waste at selected sites or selected times 9 1 10 Better site management to monitor type of waste entering HWRCs 27 6 33
Page 57 Concern about increased travel time for traders to dispose of waste 8 2 10 Lack of information about alternative disposal points 13 17 30 x Stakeholder response summary: Policy does not support SMEs in Kent economically 26 9 35 Key comments Comments indicate a misunderstanding of waste law / admission of trade disposal at HWRCs 15 18 33 x Prevent legitimate customers from entering the HWRCs e.g. van hire by householders This policy discriminates against me - age / people x Do not support determining legitimate disposal by vehicle type preferred by residents carrier vehicles for large families 3 2 5 x Clear and accessible communication will be needed to residents x Should explore potential for income from trade waste TOTAL 685 196 881 x Increase in fly tipping and cost to district councils x Open height barrier at weekend only x High level of 4x4 vehicles in Sevenoaks area – will not be able to access site x 1 district and 3 parish councils support proposal x Overarching summary: x Increased cost to districts for removal of fly tipped waste or materials presented kerbside for o 67% of respondents would support the exclusion of trade waste e.g. by ceasing to open the height collection, therefore, no overall saving to public purse barrier and excluding trade vehicles. 25% of respondents would not. x Support the policy if this limits waste from non-domestic sources o x Restricts ability of residents to move large waste items around for disposal easily Risks identified included: x Policy does not support recycling behaviours Potentially increased flytipping x The type of vehicle should be irrelevant, access should be determined by source of waste What about householders who hire vans to transport household waste or who only have use of x Suggest access for single axle domestic trailers a van? x Domestic vehicles should be permitted Instead, allow HWRCs to accept all waste from anyone - to save cost of flytipping removal and Notable sound bites gain income from materials Council should encourage all waste to be disposed / recycled responsibly “No convinced that ceasing to open the height barrier will prevent trade waste, but may prevent Implement charging scheme for traders at HWRCs instead? some legitimate residents from using the site”.
“Diverting trade / commercial waste away from HWRCs could be turning away potential revenue”
“Domestic users should not be caught in a restriction intended to prevent commercial abuse”
“The vehicle type is irrelevant they type of waste should be the deciding factor”
Household Waste Recycling Centres Public Consultation Report Page 27 of 46 6.5 Would you support the exclusion of construction waste, which the Household Waste Recycling Centres have no duty to accept and costs the Council money? (Question 9) x Customer response summary: Total Most Number of Number of number popular Theme of comments online paper of comments 9% comments comments comments - ranked Increase in flytipping 267 115 382 1 Penalises the DIYer, should be a provision to dispose of 180 60 240 2 26% Yes Charge for ALL construction waste regardless of its source 66 18 84 3 No Lack of information about alternative disposal points 50 18 68 4 Don't know Confusion as to the definition of the term 65% 'construction waste' within this question 28 9 37 Policy risks contamination of other waste streams e.g. residual 4 1 5 Recycling should be encouraged and made easy 18 2 20 Support a limit on quantity not total exclusion 19 5 24 Would support if alternative disposal points were accessible 14 3 17 Only commercial construction waste should be excluded 37 7 44 x Stakeholder response summary: Hazardous nature of material, needs managing
Page 58 Key comments properly 9 1 10 SMEs should be allowed to use HWRCs 25 0 25 x Confusion over what is meant by ‘construction waste’ – municipal or commercial? Comments indicate a misunderstanding of waste law x Increased cost to districts for removal of fly tipped waste or materials presented kerbside / admission of trade disposal at HWRCs 8 4 12 for collection, therefore, no overall saving to public purse Increased carbon emissions if householders are x Restriction on quantity will increase number of journeys made by householders – required to make multiple journeys 3 1 4 increase in carbon emissions Charge for ALL construction waste regardless of its x Policy is not in line with Vision for Kent or Kent Environment Strategy source 14 1 15 x The quantity limit is too low Create a separate 'time' for traders to use sites 3 0 3 x Loss of valuable commodity These are valuable materials which generate an x Need for robust enforcement strategy and costly to enforce at HWRCs income 40 5 45 x Request from district council for fly tipping funding TOTAL 785 250 1035
Notable sound bites “Limiting quantity will increase the number of trips by the user to dispose of the same amount of waste” x Overarching summary: o 65% of respondents would support the exclusion of construction waste at HWRCs. 26% would not. “Believe to be a too great a step between the very small quantity of rubble that could be o Risks were identified including: disposed of in 2 sacks and the very large capacity obtained by the hiring of a skip” Potential increase in flytipping Concern over penalising the DIYer, should be a provision to dispose of Charge for ALL construction waste regardless of its source? Lack of information about alternative disposal points
Household Waste Recycling Centres Public Consultation Report Page 28 of 46 6.6 Do you believe it is reasonable for householders who do not live in Kent, and therefore do not contribute to the funding of sites, to be excluded from using Kent’s x Customer response summary: Household Waste Recycling Centres? (Question 11) Total Most Number of Number of number popular Theme of comments online paper of comments comments comments comments - ranked 7% Reciprocal arrangement with neighbouring councils is required; balance across border; petty proposal 188 99 287 1 Risk of increased flytipping from restrictions 175 49 224 2 Convenience to use nearest HWRC regardless of Yes borders 139 73 212 3 34% Environmental impact from increased distance to No sites 125 16 141 4 Don't know 59% Should be encouraging recycling not deterring 102 29 131 5 Boundaries shouldn't matter to customer services 113 15 128 6 Support proposal to ban cross border users 40 12 52 Question is loaded 2 0 2 Additional tonnages will yield additional income for KCC 86 28 114 Costly to administer and police permit scheme; cost outweighs savings 93 42 135 Cross border users put pressure on Kent services 3 0 3 TOTAL 1066 363 1429 Page 59
x Stakeholder response summary: x Notable customer sound bites: Key comments “In the larger picture we are all UK residents and we all pay national and local taxes, therefore it is from x This is as long as it is short on ‘public purse’. We need to work together for things to work smoother.” Does this include the relationship with Medway x “The borders between counties are national for tax purposes. Do you propose border guards?” x Negative impact on residents purse – funding of longer journeys x Does not encourage recycling x Duty to co-operate with neighbouring councils x Difficult to police the policy x Overarching summary: x Costly to introduce the policy o 59% of respondents believe it is reasonable for householders who do not live in Kent to be x Greater carbon impact from increased journey times excluded from using Kent’s HWRCs. 34% of respondents do not believe it would be reasonable. o Risks were identified including: Notable sound bites Reciprocal arrangement with neighbouring councils is required; balance across border; petty “Residents will wish to use their nearest facilities whether across the county border or not”. proposal Increase in flytipping “Common sense says use the nearest facility” Convenience to use nearest HWRC regardless of borders Environmental impact from increased distance to sites Should be encouraging recycling not deterring Boundaries shouldn't matter to customer services
Household Waste Recycling Centres Public Consultation Report Page 29 of 46 6.7 Do you believe that councils should increase income by maximising the diversion of household waste for recycling? (Question 10)
6% 4%
Yes No Don't know
90%
x Overarching summary: o 90% of respondents believe that councils should increase income by maximising the diversion of household waste for recycling.
6.8 Do you use Household Waste Recycling Centres in other areas? (Question 12)
8%
Yes No
92%
x Overarching summary: o 8% of respondents use HWRCs in other areas. o Of those that do use HWRCs in other areas, 57% use Medway sites.
Page 60 Household Waste Recycling Centres Public Consultation Report Page 30 of 46 7 INFRASTRUCTURE INVESTMENT: CONSULTATION RESPONSES
7.3 Thinking of the Council’s aim to continuously improve sites, do you believe that the Household Waste Recycling Centres are generally fit for purpose? (Question 13)
5% 5%
Yes No Don't know
90%
x Customer response summary: Total Most Number of Number of number popular Theme of comments online paper of comments comments comments comments - ranked HWRC too small and poorly designed 56 24 80 1 Negative experience of queues to access HWRC and congestion 34 8 42 2 Need to increase material streams 23 8 31 3 Site staff - unhelpful and too many 17 5 22 4 Re-use / shop facility on sites wanted 14 2 16 Opening hours - increase 10 1 11 Greater extraction of recyclate from residual stream 11 2 13 Accessibility of containers and manual handling difficulties 8 3 11 Pedestrian issues on site 7 1 8 Lack of access for over height vehicles 8 0 8 Site signage improvements needed 4 0 4 Journey time from home too great 4 0 4 TOTAL 173 45 219 x Overarching summary: o 90% of respondents believe that the HWRCs are generally fit for purpose. o Key criticisms of the centres included: HWRC too small and poorly designed Negative experience of queues to access HWRC and congestion Need to increase material streams Site staff - unhelpful and too many
Household Waste Recycling Centres Public ConsultatiPageon 61 Report Page 31 of 46 7.4 To help shape the future network of Household Waste Recycling Centres, please tell us which of the following are the three most important to you. (Question 14) Short or no queues to 0.5% enter sites 0.5% 7% The range of materials 17% 2% accepted for recycling Ease of access around the site 17% Short journey time from home to site Helpful site staff
25% No steps on site
Undercover site 19% Clear on site signage 13% Other
x Customer response summary: Total Most Number of Number of number popular Theme of comments online paper of comments comments comments comments - ranked Improve safety - ease of exit, site design, larger signage 1 7 8 1 Re-use / shop facility on sites wanted 5 2 7 2 Longer opening hours 4 2 6 3 Allow access to people on foot 3 2 5 Increase materials accepted - plastics 3 1 4 More publicity about HWRCs 1 0 1 Better customer care from site staff 1 0 1 Staff that are able to make a decision without hiding behind health and safety 1 0 1 Clean and clear sites and entry roads 2 0 2 TOTAL 21 14 35 x Overarching summary: o Most respondents identified the range of materials accepted on site as one of the most important factors of HWRCs. o Short journey times, short queues at the site, helpfulness of site staff and ease of access around the site as important. o Many respondents specified a desire for a reuse facility on site and longer opening hours.
Page 62 Household Waste Recycling Centres Public Consultation Report Page 32 of 46 7.5 Would you support an overall reduction in one or two sites across Kent, provided the service continued to be operated to a good standard across the remainder of Household Waste Recycling Centres? (Question 15)
x Customer response summary: 15% Total Most Number of Number of number popular Theme of comments online paper 30% of comments comments comments comments - ranked Increased fly tipping 405 160 565 1 Yes Increased travel time / cost / inconvenience 330 212 542 1 No Number of sites needs to be increased, not Don't know reduced 198 67 265 2 Less sites will lead to less recycling 155 20 175 Negative environmental effect 114 20 134 Increased queues, traffic and pressure at other sites 103 28 131 55% Need to improve services to make money / improve income generation 29 10 39 Not enough info provided to be able to comment 22 5 27 Reduction in employment 4 2 6 Page 63 TOTAL NUMBER OF COMMENTS 1,338 519 1,857
x Stakeholder response summary: Key comments x Overarching summary: x Ensure sufficient capacity at sites – footfall and tonnages o 30% of respondents would support an overall reduction in one or two sites across Kent, provided the x Reducing number of HWRCs is not conducive to reducing waste to landfill service continued to be operated to a good standard across the remainder of HWRCs. o x A 20 minute drive time guideline is supported 55% of respondents would not support an overall reduction. o Risks were identified including: Notable sound bites Increase in flytipping Convenience to use nearest HWRC regardless of borders “Sites should be local to populations and within a 20 minute drive time” Increased travel time / cost. Environmental impact from increased distance to sites Should be encouraging recycling not deterring Boundaries shouldn't matter to customer services
Household Waste Recycling Centres Public Consultation Report Page 33 of 46 7.6 Taking into account proposals to improve the facility at Ashford, do you believe it is reasonable to close the out of date and expensive to operate site at Hawkinge, provided services exist within a 20 minute drive time of your home? (Question 16)
x Customer response summary: Total Most Number of Number of number popular Theme of comments online paper of comments comments comments comments - ranked 36% Other HWRCs are too far to travel 69 27 96 1 Yes Improve Hawkinge HWRC 25 7 32 2 46% No Increase flytipping 24 8 32 2 Don't know Increase in fuel cost to residents and pollution from increased journeys 19 9 28 4 Closure would increase costs to councils e.g removal of flytipping; further to haul waste 3 0 3 18% Should expand number of HWRCs not reduce them 7 3 10 The questions are biased and leading 4 2 6 The HWRC is a service to the community and is convenient 8 8 16 Need the HWRC as alternate weekly collections are The graph below excludes those that answered ‘don’t know’ not sufficient 0 0 0 Adverse effect on recycling 5 5 10 Increased congestion at alternative HWRCs 12 7 19
Page 64 There will be a local increase in housing development - the HWRC is needed 9 8 17 33% Find ways to reduce the operating costs of the HWRC to allow it to remain open 2 3 5 Yes Why is the Hawkinge site so expensive to operate 0 0 0 No TOTAL 187 87 274
67%
x Overarching summary: o 36% of all respondents believed it is reasonable to close the site at Hawkinge. o 46% of respondents answered they ‘did not know’ – after excluding these responses, 67% of the remaining respondents believed it is reasonable to close the site at Hawkinge. o Further analysis reveals that of those respondents that use Hawkinge HWRC, 92% believe it should not be closed. x Stakeholder response summary: o The main reasons that people answered ‘no’ to closing Hawkinge HWRC are: Journey times will be increased Key comments Hawkinge should be improved/ updated Increase in flytipping Shepway DC support – provided no additional cost is incurred by the district, but does x Increase in fuel cost to residents and pollution from increased journeys ask KCC to seriously consider Hawkinge is a growing town/ area and needs it’s own HWRC x Closure not supported by local parish and town councils Some respondents state that the question is loaded and misleading x Increase in travel time and associated journey cost and emissions; risk of flytipping Some state that Ashford HWRC is more than 20 minutes away/ too far to travel to x Support reduced number of materials accepted to reduce operating costs x Misleading question and unsubstantiated statement – “out of data and expensive to operate” x Ambiguous question – transfer station or HWRC for closure? x Concerns about impact on Whitfield and Folkestone HWRCs
Household Waste Recycling Centres Public Consultation Report Page 34 of 46 7.7 Taking into account that there is a facility at Deal and at Margate, do you believe it is reasonable to close the out of date and expensive to operate site at Richborough, Customer response summary: provided services exist within a 20 minute drive time of your home? (Question 17) x Total Most Number of Number of number popular Theme of comments online paper of comments comments comments comments - ranked Other HWRCs are too far to travel 32 37 69 1 The road infrastructure does not make the alternative 42% 41% Yes HWRCs easily accessible 34 20 54 2 No The HWRC is always busy and shouldn't be closed 17 14 31 3 Don't know Increase flytipping 12 14 26 4 Closure would increase costs to councils e.g. removal of flytipping; further to haul waste 3 3 6 Improve Richborough HWRC 9 1 10 17% Should expand number of HWRCs not reduce them 2 4 6 The questions are biased and leading 1 1 2 The HWRC is a service to the community and is convenient 4 13 17 The graph below excludes those that answered ‘don’t know’ Adverse effect on recycling 9 5 14 Increase in fuel cost to residents and pollution from increased journeys 13 7 20 There will be a local increase in housing development - the HWRC is needed 3 1 4 Page 65 28% Find ways to reduce the operating costs of the HWRC to allow it to remain open 5 0 5 Why is the Richborough site so expensive to operate 6 2 8 Yes TOTAL 150 122 272 No
72% x Overarching summary: o 41% of all respondents believed it is reasonable to close the site at Richborough. o 42% of respondents answered they ‘did not know’ – after excluding these responses, 72% of the remaining respondents believed it is reasonable to close the site at Richborough. o Further analysis reveals that of those respondents that use Richborough HWRC, 80% believe it should not be closed. Stakeholder response summary: x o The main reasons that people answered ‘no’ to closing Richborough HWRC are: Key comments Journey times will be increased – 20 minutes is too far x Additional journey time for residents to alternative HWRCs The road infrastructure does not make the alternative HWRCs easily accessible x Adverse traffic impacts on local road network around Deal and Whitfield – review and advantage Increase in flytipping taken of Section 106 Town and Country Planning Act 1990 for highway improvements The HWRC is always busy and shouldn't be closed x Several responses do not support the closure o A few respondents commented that Richborough HWRC should stay because the Thanet Waste is x Deal Transport and Flood Alleviation Study – infrastructure assessment being expanded. x Margate HWRC necessitates a longer walk with heavy items x Please consider older people who would have further to drive x Increase in flytipping x How is the site out of data? x Location provides a service to southern half of the Thanet district Notable sound bite “If it is an expensive site, why not replace with a more modern facility to reduce costs”
Household Waste Recycling Centres Public Consultation Report Page 35 of 46 7.8 The Household Waste Recycling Centres at Dartford Heath and Swanley currently operate at full capacity with no scope for expansion. Do you agree they should be replaced with modern facilities? (Question 18)
44% Yes 50% No Don't know
6%
The graph below excludes those that answered ‘don’t know’
10%
Yes No
90%
x Overarching summary: o 50% of respondents believe that the Household Waste Recycling Centres at Dartford Heath and Swanley should be replaced with modern facilities. o Further analysis reveals that of those respondents that use Dartford Heath and Swanley HWRC, 47% believe they should be replaced with modern facilities. o The main reasons that people answered ‘no’ to replacing Dartford Heath and Swanley with more modern facilities are: Respondents believe that the sites are fine as they are Respondents are concerned that updating them would mean moving them to one site rather than two separate sites Some respondents feel that there is not enough information provided to make judgement e.g. what is meant by ‘modern facilities?’ o Dartford Borough Council supported this proposal.
Page 66 Household Waste Recycling Centres Public Consultation Report Page 36 of 46 7.9 Do you agree that the Household Waste Recycling Centre at Church Marshes, Sittingbourne, is inadequate and should be replaced with a new facility at a more accessible location, to provide a more efficient service to Swale residents? (Question 19)
24%
Yes 4% No Don't know
72%
The graph below excludes those that answered ‘don’t know’
16%
Yes No
84%
x Overarching summary: o 24% of respondents believe that the HWRC at Church Marshes should be replaced with a new facility in a more accessible location. o Further analysis reveals that of those respondents that use Church Marshes HWRC, just 40% believe it should be replaced with a new facility. o The main reasons that people answered ‘no’ to replacing Church Marshes with a new facility in a more accessible location are: Respondents are happy with Church Marshes as it is Many respondents are concerned that this will result in the closure of Sheerness/ Faversham HWRC Some respondents feel there is not enough information provided on where the new site would be o Stakeholder comments included: Maidstone BC support relocation of HWRC and Transfer station to reduce congestion and access are improved May deter flytipping Would reduce vehicle emissions Care to identify location which doesn’t impact environmentally sensitive land
Page 67 Household Waste Recycling Centres Public Consultation Report Page 37 of 46 7.10 Do you support the provision of an additional Household Waste Recycling Centre in the Tonbridge and Malling area, which is currently not covered by the existing network? (Question 20)
45% Yes 52% No Don't know
3%
The graph below excludes those that answered ‘don’t know’
6%
Yes No
94%
x Overarching summary: o 52% of respondents support the provision of an additional HWRC in the Tonbridge and Malling area. o Stakeholder comments include: Widespread from organisations for a HWRC in the area Improving access to existing sites should be considered before building new HWRCs Recognised over-crowding at some existing sites e.g. Tovil High level of illegal waste sites in mid Kent EA support for HWRC development in Staplehurst / Headcorn area “Additional sites should be considered on journey time and not differentiated by district boundaries” “It is no coincidence that the mid Kent area, where there is no HWRC, has the highest number of illegal waste sites”
Page 68 Household Waste Recycling Centres Public Consultation Report Page 38 of 46 7.11 Do you support the upgrading of the existing Household Waste Recycling Centre at Ashford, which forms part of the proposal for a new waste transfer station (which bulks household waste for haulage to reprocessors)? (Question 21)
Yes 46% 50% No Don't know
4%
The graph below excludes those that answered ‘don’t know’
7%
Yes No
93%
x Overarching summary: o 50% of respondents would support an upgrading of the existing HWRC at Ashford. o Further analysis reveals that of those respondents that use Ashford HWRC, 88% support the upgrading of the site. o Stakeholders demonstrated support for upgrading of HWRC and provision of new transfer station.
Page 69 Household Waste Recycling Centres Public Consultation Report Page 39 of 46 7.12 If you do not use a Kent Household Waste Recycling Centre, are there any improvements that would encourage you to? (Question 22)
15%
Yes No
85%
It is important to be aware that although this question is directed at people who currently don’t use the HWRCs, a number of people who answered this question ARE current HWRC users. x Customer response summary: Total Most Number of Number of number popular Theme of comments online paper of comments comments comments comments - ranked Local facilities - want a site on my doorstep 37 19 56 1 Extend range of materials accepted 21 19 40 2 Improve site accessibility and safety e.g. no steps, low access to containers 15 11 26 3 Consistency of service provided at HWRCs 5 3 8 4 Shorter queues 3 3 6 Extended opening hours 7 2 9 Allow over height domestic vehicles 6 1 7 Wish to purchase recycled products e.g. compost 9 1 10 Access for pedestrians 4 7 11 More helpful site staff 5 2 7 Improved signage 3 1 4 Greater access to HWRC information prior to visit 2 2 4 Reassure me that the materials are recycled 2 2 4 TOTAL x Overarching summary: o The main suggested improvements include: Many want on-site shops to buy things that are still in good condition Many want to be able to recycle more things especially plastics A facility closer to home/ more sites Allow over height vehicles More helpful staff More help with carrying heavy items Better/ more parking on site Mobile collections from home for elderly and people without a car Increase the opening hours Improve the ease of access No steps o Many commented that there wasn't the opportunity in the questionnaire to suggest improvements for those that already use the HWRCs. Page 70 Household Waste Recycling Centres Public Consultation Report Page 40 of 46 7.13 Other miscellaneous notable comments
Stakeholder key comments Customer key comments x Do not support the reduction and accessibility x The sites were built when they accepted just of the service as a way of preventing trade one product: waste. To be fit for purpose for waste. the 21st century means having the space and x Increased cost to districts for removal of fly infrastructure to separate items so that tipped waste or materials presented kerbside materials can be re-used or recycled. That for collection, therefore, no overall saving to means the Council has to have a programme public purse. of modernisation. It also means that residents x Questions are somewhat misleading e.g. sites shouldn't have a 'postcode lottery' on what is are out of data and expensive to run available to them in their local areas. The site x Gaining income from trade waste disposal will at Pepperhill should be the goal for all be more economically effective than attempting residents to have access to, not just a few. to cut costs from excluding non-householder x If the height barrier were not opened for them waste” you are excluding the very people that pay x Lack of understanding by businesses as to how taxes towards this service. to legally dispose of waste should be tackled x Normal householders who cannot afford to pay before making further attempts to ban them for the council collection often ask for friends from HWRCs. or family with large vehicles to take large items x Measures need to be put into place to monitor to the tip for them. This would discriminate levels of fly tipping if policies are implemented. against people on low income or the elderly. x Proposals should be deferred until presented to x Because I need to dispose of waste for my Locality Boards. business. x KCC should undertake further consultation on x Because experience shows that if you restrict each local site and provide further detailed either collection/recycling or civic amenity sites analysis. you get fly tipping which costs considerably x Short / no queues are important to people. more to clean up. This is a short term saving x Limitations on waste are too severe. leading to long term increased expenditure
Stakeholder sound bites Customer sound bites “Should be emphasising opportunities to recycle “The money spent on developing the new site is not reducing them” offset by the cost saving associated with reduced fly tipping.” “The Council should aim to increase income by maximising diversion of all waste”
“If profit is available from waste then it should be the business of KCC to chase it, even if trade waste is available to turn into profit”
Page 71 Household Waste Recycling Centres Public Consultation Report Page 41 of 46 8 CONSULTATION RESPONSES: CURRENT SERVICE PROVISION
8.3 How often do you visit a Kent County Council Household Waste Recycling Centre? (Question 1)
4% 10%
40% Never Weekly 22% 2-3 times a month Monthly A few times a year
24%
8.4 How do you rate the current service provided at your local Household Waste Recycling Centre? (Question 2)
2% 13%
40% Poor Acceptable Good Excellent
45%
8.5 Which Household Waste Recycling Centre(s) do you use most often? (Question 3)
Online Questionnaire Paper Questionnaire
300
250
200
150
100 Number of respondents of Number 50
0 ) ll ey ge m ad ss nl in ther acon Tovil a k Ro ncliffe ne w ll r er O Le rne Bay Dunbrik rt d (Dover) Sw epperhi he He el chborough Ha h Marshes P Sho ha i c FavershamNorth Far S itfi R auxha artford Heath C V D New RomneyManston Road Wh Chur
Southwall Road (Deal * Please note: these numbers will be influenced by communicationsPage 72 that have occurred in different areas of Kent Household Waste Recycling Centres Public Consultation Report Page 42 of 46 8.6 How long does it take to get to your nearest Household Waste Recycling Centre from your home? (Question 4)
9%
42% Less than 10 minutes Between 10 - 20 minutes More than 20 minutes
49%
8.7 What do you think is a reasonable drive time to a Household Waste Recycling Centre? (Question 5)
4% 25%
Less than 10 minutes Between 10 - 20 minutes More than 20 minutes
71%
Page 73 Household Waste Recycling Centres Public Consultation Report Page 43 of 46 9 CONSULTATION RESPONSES: “ABOUT YOU”
9.3 Gender
4%
Male 36% Female Do not wish to declare 60%
9.4 Age range
1% 4% 5% 14% Up to 19 27% 20-25 26-35 36-45 46-55 20% 56-65 Over 65 Do not wish to declare 29%
9.5 Do you consider yourself to be disabled?
5% 5%
Yes No Do not wish to declare
90%
Page 74 Household Waste Recycling Centres Public Consultation Report Page 44 of 46 9.6 What is your sexual orientation?
29% Heterosexual Bisexual Gay 0.3% Lesbian Do not wish to declare 1% 69% 1%
9.7 What is your religion / beliefs?
Christian 26% Buddist Hindu Jewish 49% Muslim Sikh Other No religion 24% Do not wish to declare 1%
9.8 What is your ethnic group?
Asian Chinese 1% Asian Indian 18% Asian Pakistani
Black African
Black Carribean 2% M ixed_White and Asian
M ixed_White and Black African
7 M ixed_White and Black Carribean
White English_Welsh_Scottish_Northern Irish_British White Gypsy or Irish Traveller
White Irish 79% Other
Do not wish to declare
Page 75 Household Waste Recycling Centres Public Consultation Report Page 45 of 46 10 POST CONSULTATION
Recommendations were presented to Cabinet on 19th March 2012 for consideration which took into account the feedback obtained from the public consultation and the full EIA. You can view the Cabinet paper.
Cabinet endorsed all recommendations and delegated the final decision to the Cabinet Member for Environment, Highways and Waste.
A petition was received in respect of the proposal to close the Richborough HWRC. This was debated at the meeting of the County Council on Thursday 29th March 2012.
The Cabinet Member made his decision on 3rd April 2012 and a full copy of this can be found on our website.
Operational policy changes at HWRCs will be implemented during the summer of 2012, with extensive customer engagement to inform and support customers.
Page 76 Household Waste Recycling Centres Public Consultation Report Page 46 of 46 Appendix D
EQUALITY IMPACT ASSESSMENTS
KENT HOUSEHOLD WASTE RECYCLING CENTRES
May 2011- February 2012
EIA HWRC Review 2011 - 12 Page 77 1 KENT COUNTY COUNCIL
EQUALITY IMPACT ASSESSMENT
Directorate: Enterprise and Environment
Name of policy, procedure, project or service
Household Waste Recycling Centre (HWRC) Review
Type What are you impact assessing, a policy procedure or service?
The Household Waste Recycling Centre service and its operating policies
Responsible Owner/ Senior Officer Provide the name of the senior officer or manager responsible for the policy, procedure, project or service
Caroline Arnold, Head of Waste Management
Date of Screenings:
A: Initial screening: Thursday 18th May 2011 Pages 3 - 9 B: Interim screening: Tuesday 13th September 2011 Pages 10 - 15 C: Final screening: Thursday 16th February 2012 Pages 16 - 24
EIA HWRC Review 2011 - 12 Page 78 2 A: Initial EIA conducted at start of HWRC Review process (May 2011) – prior to development of proposed policies
Screening Grid:
Characteristic Could this policy, Could this policy, Assessment of Provide details: procedure, project or procedure, project or potential impact a) Is internal action required? If yes, why? service affect this service promote equal HIGH/MEDIUM/LOW/ b) Is further assessment required? If yes, why? group differently from opportunities for this NONE/UNKNOWN c) Explain how good practice can promote equal others in Kent? group? opportunities YES/NO YES/NO Positive Negative Unknown Unknown Further assessment will be required once the Age proposals to HWRC services are known. Yes Consideration may need to be given to journey times, physical access to site and use of containers. Unknown Unknown Further assessment will be required once the
Page 79 Disability proposals to HWRC services are known.
Consideration may need to be given to journey times, Yes physical access to site and use of containers.
Enforcing exclusion of trade waste users has the potential to ease site congestion improving manoeuvrability. None None No Gender None None No Gender identity Unknown Unknown Further assessment will be required once the Race proposals to HWRC services are known. Yes Mosaic analysis to be used to determine composition of population to identify dominant languages of minority groups. Unknown Unknown Further assessment will be required once the Religion or belief Yes proposals to HWRC services are known.
EIA HWRC Review 2011 - 12 3 Research to understand religious festivals and cultural needs of people living in areas with proposed changes in service. None None Sexual orientation No
Unknown Unknown Further assessment will be required once the details Pregnancy and of changes to HWRC services are known. Yes maternity
Marriage and civil No None None partnership Page 80
EIA HWRC Review 2011 - 12 4 Part 1: INITIAL SCREENING (May 2011)
Context Kent County Council has the statutory responsibility to manage the disposal of municipal waste in Kent. As part of this, the service runs 19 Household Waste Recycling Centres (HWRC) where householders can bring a variety of municipal waste for recycling and disposal. This service has been under scrutiny for some time and a review has been commissioned to examine the shape of future operations to and any efficiency savings.
Aims and Objectives The aim of the review is to identify the right level of HWRC service for Kent residents at the right cost. The review will include an assessment of the HWRC network in terms of economy (costs and income generation), efficiency (productivity), effectiveness (customer satisfaction, recycling rates, material types and capture) and location.
The review will examine the current provision and location of HWRCs, their operating policies, the potential for increasing income, as well as the options for making the required savings.
Beneficiaries The intended beneficiaries are householders as users of the Household Waste Recycling Centre service in Kent. A review of HWRC service provision will examine a range of policies. These policies will seek to provide appropriate HWRC services for householders whilst yielding savings.
Consultation and data In order to understand the customer base currently using the HWRC service, data is to be sourced and collated through the website and face to face surveys at all HWRCs and conducted by KCC Waste Service Officers (WSO). To ensure statistical validity, a threshold has been set requiring a minimum of 200 surveys per site per year, equalling a minimum of 3,800 surveys across the customer base.
Potential Impact This Equality Impact Assessment (EIA) is an initial screening to indicate potential areas of impact, both positive and negative, to the diverse population of Kent, should any new policy changes be implemented.
Currently five of the Protected Characteristics may potentially be impacted either positively or negatively and will require further research when service delivery models are proposed by Members. This EIA will then be developed to detail the nature of the positive and negative impacts and mitigations.
EIA HWRC Review 2011 - 12 Page 81 5 JUDGEMENT
Option 1 – Screening Sufficient NO
Option 2 – Internal Action Required YES
There is potential for adverse impact on particular groups should service changes be proposed and implemented (see action plan1).
An interim EIA (pages 10 -15) will be conducted once Members have agreed the proposed policy / service changes.
This initial EIA screening has demonstrated the value that further data would bring to inform the interim and full EIAs. This data will be used in conjunction with Mosaic’s Kent and Medway segments and afford wider visibility of the equality impacts.
Of particular note is the need to undertake a period of public consultation to gain a better understanding of the impacts that these changes may have on Kent householders.
Whilst the Informal Member Group continues with their review of the HWRC Service, Action Plan 1 (pages 7- 8) will be completed to provide the necessary information to inform the interim EIA and the development and delivery of a public consultation.
Option 3 – Full Impact Assessment NO Only go to full impact assessment if an adverse impact has been identified that will need to undertake further analysis, consultation and action
Option 3 will be conducted within the interim EIA (page 10) and re-assessed following public consultation / full EIA (page 16).
EIA HWRC Review 2011 - 12 Page 82 6 Action Plan 1- Initial Equality Impact Assessment (May 2011)
Protected Issues identified Action to be taken Expected Owner Timescale Cost Characteristic outcomes implications Further customer Sample of customer To provide customer Caroline September Achievable AGE insight of age postcodes to be insight – identify Arnold 2011 through composition of collected with Mosaic indicative age existing HWRC service profiling to provide composition of resources. users required. customer segmentation. HWRC service users. Methods of Use Mosaic data to engagement for develop appropriate To effectively public consultation engagement channels engage with a cross may not suit all which suit preferences section of ages of adults that form our across age ranges – not adults within the customer base. a one size fits all consultation.
Page 83 approach. Identify key groups to consult with. Accessibility of Ensure alternative Public consultation Caroline October TBC DISABILITY public consultation formats are available accessible by all Arnold 2011 documents. including Easy Read; adults. helpline number Identify key groups provided; Plain English Feedback / lessons to consult with. applied to materials learnt from published. consultation shared within Kent County Council to ensure high quality consultations are delivered to Consider customers. accessibility to Consider use of Talking service information Newspapers and radio to Increase awareness for people with print communicate service of the HWRC impairments. information. service.
EIA HWRC Review 2011 - 12 7 Protected Issues identified Action to be taken Expected Owner Timescale Cost Characteristic outcomes implications KCC engagement Equality /diversity To equip officers Caroline September £700 for RACE with minority training for officers who with appropriate Arnold 2011 external trainer. & groups to obtain are required to conduct skills, knowledge RELIGION OR service feedback. face to face customer and understanding, Remaining BELIEF satisfaction surveys at to effectively actions HWRCs. engage with achievable Understanding of customers from through minority groups’ Provide officers with different cultures existing usage of HWRC KCC’s ‘Race, Faith and and from minority resources. services. Culture’ toolkit as a groups, to obtain reference guide. feedback Identify key groups respectfully and with to consult with. Sample of customer confidence. postcodes to be
Page 84 collected with Mosaic To provide customer profiling to provide insight; indicate customer segmentation. service use by minority groups. To identify areas of Audience segmentation Inform delivery of Caroline September Achievable PREGNANCY Kent where to understand where public consultation Arnold 2011 through OR pregnancy and HWRCS may have to ensure feedback existing MATERNITY maternity may be higher than average is gained from those resources. more prevalent and levels of customers who within protected / or concentrated are pregnant and/ or with characteristic group. and sensible to small children. ensure public Communication consultation is well Mosaic profiling of methods selected communicated. customer sample to meet needs and examine communication support effective preferences for parents engagement for who are pregnant and / public consultation. or have small children.
EIA HWRC Review 2011 - 12 8 Initial EIA - Sign Off
I have noted the content of the equality impact assessment and agree the actions to mitigate the adverse impact(s) that have been identified.
Senior Officer
Signed: Date: 18th May 2011 Name: Caroline Arnold Job Title: Head of Waste Management
Directorate Equality Lead
Signed: Date: Name: Job Title:
EIA HWRC Review 2011 - 12 Page 85 9 B: Interim EIA conducted prior to public consultation of HWRC Policy / service changes (September 2011)
FULL ASSESSMENT:
1. Scope of the Assessment This assessment sets out to understand more fully, the potential impacts that may result from the proposed policy changes to the HWRC service to householders wishing to dispose of or recycle household waste.
x Stop accepting tyres, gas bottles and asbestos x Limit building waste to 2 x 30 litre sacks per car x Stop opening the height barrier except on Saturdays x Exclude all vans, pick-ups, flat bed vehicles, over-sized recreational vehicles and trailers x Consider the introduction of a permit scheme for residents in areas bordering other counties x Close Hawkinge HWRC summer 2013 x Close Richborough HWRC summer 2013
2. Information and data The initial screening highlighted improvements that could be made to data and subsequently knowledge about our customers and the potential impacts of service changes upon them. The tasks set out in Action Plan 1 (pages 7-8) have provided valuable information to inform a full EIA assessment prior to public consultation.
Please note a further EIA (C) will be conducted once the public consultation has been completed.
HWRC Customer insight:
Customer insight information has allowed KCC to understand the current customer base for the HWRC service and has also highlighted characteristics of those who are less likely to be service users:
¾ Those without access to a vehicle ¾ Elderly and younger people ¾ Ethnicity – English may not be first language ¾ Adults who have children and may be a single parent (or have nobody to leave children with do not want to take them to HWRC) ¾ Householders with no gardens and who have their waste management needs met by kerbside collection schemes ¾ Transient populations where they are not requiring the service due to limited stay in Kent.
Clearly communities are diverse so you will find pregnant, elderly, disabled people and ethnic minority groups across Kent, however, there are areas where some of these characteristics are more prevalent. This has been considered within this EIA and in
EIA HWRC Review 2011 - 12 Page 86 10 planning the public consultation to ensure proportionate access to information and opportunity to respond to proposals.
3. Involvement and Engagement Drawing upon data collated and information available to KCC, a consultation engagement plan has been produced to ensure accessibility to the consultation by Kent residents.
Communications have been tailored for householders to factor in elements such as how certain groups of people prefer to be communicated with.
The public consultation will use the following communication channels. Collectively, these will ensure strong coverage across the county for all residents.
x HWRC site signage x Information handed to HWRC customers at all 19 HWRCs x Consultation questionnaire posted to sample of householders who are receptive to direct mail x Postcard signposting consultation online, posted to a sample of householders who are receptive to direct mail and are Internet users x Gateway information screens across Kent x Information available at sport clubs, gyms to reach a section of the current customer base x Press advertisement in leading Kent press titles across Kent x Older people’s forums x Disability groups / organisation x Religious networks x Minority groups – Gypsy and Irish Travellers x KCC Community engagement officers local contact x Posters in community facilities e.g. schools, village halls x KCC web site x Information to all parish / town councils
EIA HWRC Review 2011 - 12 Page 87 11 Repeat Screening Grid: Interim EIA (September 2011)
Characteristic Could this policy, Could this policy, Assessment of Provide details: procedure, project or procedure, project or potential impact a) Is internal action required? If yes, why? service affect this service promote equal HIGH/MEDIUM/LOW/ b) Is further assessment required? If yes, why? group differently from opportunities for this NONE/UNKNOWN c) Explain how good practice can promote equal others in Kent? group? opportunities YES/NO YES/NO Positive Negative Customer information and KCC data has identified HWRCs where service users are likely to have a higher level of older residents than the Kent average. The consultation will ensure that these people are targeted proportionately and appropriately to engage in the process and obtain feedback.
Consideration has been given to waiting times, which may positively impact upon the more elderly Yes Low Low AgePage 88 customers. The proposed policies would seek to improve waiting times at HWRCs as a reduction in ‘trade’ vehicles entering the sites will ease congestion.
The proposed closure of Hawkinge1 and Richborough2 HWRCs – the nearest alternative HWRCs remain within a drive time of 10- 20 minutes which is equitable with other Kent residents. There is likely to be a positive impact for those customers with disabilities where queuing negatively impacts upon them – by restricting ‘trade’ vehicles, Yes Low Low Disability throughput of vehicles will be reduced, resulting in a faster service for the residents. This should also increase manoeuvrability on site.
1 Drive times for residents in the Hawkinge area will not exceed the 20 minute standard if the site is to close. 2 The population predicted to be effected by the potential closure of Richborough HWRC amounts to approximately 150 households which equates to 0.02% of Kent residents. These households exhibit the following characteristics: Middle aged people living in rural areas with young teenagers; some older people but active; Low ethnic diversity; Very likely to own vehicle (more than one).
EIA HWRC Review 2011 - 12 12 A low negative impact may be experienced by those who use the Richborough HWRC, as some may need to drive a little further to access the next nearest site. The drive times to the nearest site will not discriminate residents living in the Richborough area, as alternative HWRCs are available within a drive time equitable with other Kent residents.
Arrangements will be put in place to cater for residents using adapted vehicles which are over height and require the height barrier to be opened. No None None Gender No None None Gender identity Mosaic analysis tells us that ethnic minorities are
RacePage 89 unlikely to be HWRC service users currently.
Mosaic analysis has been used to determine the Yes None Low composition of the Kent population to identify dominant languages of minority groups in relation to HWRC locations. This will be catered for within the public consultation.
Information has been gained to understand Religion or belief implication of religious festivals and cultural needs of people living in areas with proposed changes in No None None service. As the proposed policies do not alter the time / days that the service is provided, a negative impact has not been assessed. No None None Sexual orientation
EIA HWRC Review 2011 - 12 13 Population profile data has been used to identify Pregnancy and areas where pregnancy and maternity may be higher maternity than the Kent average, as well as communication preferences.
There is likely to be a positive impact where queuing negatively impacts upon them – by restricting ‘trade’ vehicles, throughput of vehicles will be reduced, resulting in a faster service for the residents. Yes Low Low A low negative impact may be experienced by those who currently use the Richborough and Hawkinge HWRCs, as some may need to drive a little further to access the next nearest site. The drive times to the nearest site will not discriminate residents living in the Richborough area, as alternative HWRCs are available within a drive time equitable with other Kent
Page 90 residents (please see footnote on page 12).
EIA HWRC Review 2011 - 12 14 4. JUDGEMENT
Interim EIA - Sign Off
I have noted the content of the equality impact assessment and agree the actions to mitigate the adverse impact(s) that have been identified.
Senior Officer
Signed: Date: 13th September 2011 Name: Caroline Arnold Job Title: Head of Waste Management
Directorate Equality Lead
Signed: Date: Name: Job Title
EIA HWRC Review 2011 - 12 Page 91 15 C: Part 2 - FULL ASSESSMENT (February 2012)
Name: Household Waste Recycling Centre (HWRC) Review.
Responsible Owner/ Senior Officer: Caroline Arnold, Head of Waste Management
Date of Full Equality Impact Assessment: 16th February 2012
Scope of the Assessment:
x To review the public consultation responses (following a 10-week consultation period), where a range of new policies for the future operation of the HWRC network were proposed
x To re-evaluate the impacts (positive and negative) on the Protected Characteristics in light of the consultation feedback and identify actions to prevent / limit negative impacts.
Information and Data
Key information / data used in this assessment include:
x Qualitative feedback from public consultation in relation to protected characteristics: o Customer views on proposed policies o Waste Management stakeholder views e.g. District Councils o From public bodies e.g. Parish Councils o Community stakeholders e.g. CPRE
x Quantitative feedback from public consultation in relation to protected characteristics: o Customer views on proposed policies
x Statistical information about the consultation in relation to protected characteristics: o Response rates o Diversity of respondents* o Gender and age* o Mosaic analysis of respondents set against Kent population data relating to Protected Characteristics
* Where respondents provided this information
Involvement and Engagement
Please refer to appendix i – “Household Waste Recycling Centre public consultation delivery” (page 26) which provides comprehensive information concerning the involvement and engagement activity surrounding the review of the HWRC service.
EIA HWRC Review 2011 - 12 Page 92 16 Judgement
The public consultation responses did not reveal any further impacts (negative or positive) upon any of the protected characteristics, which had not already been identified within the initial screening and interim EIA.
Action Plan
The action plan prepared in May 2011 as part of the initial EIA has been fully delivered. Evidence and outcomes of this delivery is provided in table 3 on page 18.
A further action plan (page 21) has been prepared to reflect the potential impacts should Members adopt some, or all of the policies proposed in the HWRC review.
Monitoring and Review
The proposed policies for the HWRC service will be presented to KCC Cabinet on 19th March 2012, where a decision will be made to implement, reject or amend each policy.
EIA HWRC Review 2011 - 12 Page 93 17 Table 3: Record of consultation engagement mechanisms with residents likely to exhibit protected characteristics and response.
Protected Engagement mechanisms informed by initial EIA Consultation response Characteristic screening and interim EIA x Proactive targeting of older residents / HWRC customers (group 1) x Direct mail was selected for older population (group 1) by direct mail (consultation questionnaire) in the Canterbury, as their preferred communication channel. This Maidstone and Thanet districts, where proportion of elderly audience are unlikely to have access and use the residents is the greatest. Internet and, therefore, unable to complete an online questionnaire. x Direct mail was up weighted in Ramsgate, Sandwich and Folkestone areas (due to proposed local HWRC closures), to x The targeted engagement achieved a 47% response provide enhanced opportunity to engage. rate to the consultation questionnaire sent.
x A further direct mail (information postcard) was sent to older x 27% of respondents indicting their age were 65 years people (group 2) in the Maidstone, Sevenoaks, Tunbridge Wells, and over.
Page 94 Tonbridge and Mailing and Dartford districts – where they are receptive to direct mail and utilise the Internet. This is a separate group of people to those described in Group 1 which have been identified through Mosaic. Age x Kent wide press advertising provided an engagement opportunity for the most elderly communities in Kent, who are known to be high consumers of local press titles.
x In addition, sporting groups such as bowls clubs were provided with consultation information, as it is recognised that this sport attracts an older player.
x Information was sent to Older People Forums and associated groups across all 12 districts.
x Large print format made available for people with visual impairments.
EIA HWRC Review 2011 - 12 18 Protected Engagement mechanisms informed by initial EIA Consultation response Characteristic screening and interim EIA x A range of alternative formats for the consultation questionnaires x Large print format - 2 requests was provided to cater for diverse needs. x Easy Read – 1 requests Disability x Information was sent to a range of disability groups across Kent. x Plain English – used throughout the materials x Braille format - no requests x Information was sent to all KCC Staff Groups for equality and diversity. x Verbal presentation of questionnaire – 4 requests x Audio format – made available online x 5% of respondents reported to have a disability
Gender N/A x 60 % of respondents were male / 36% female Gender- N/A N/A Page 95 identity x A direct mail (information postcard) was sent to Mosaic groups x Alternative languages – no requests more likely to include people from ethnically diverse backgrounds Approximately 8.5% of respondents who provided a in the Canterbury, Dartford, Gravesham, Maidstone, Shepway, x postcode belong to a Mosaic group more likely to Thanet, Tunbridge Wells and Tonbridge and Malling districts. include ethnically diverse people x Questionnaire made available in alternative languages. x Respondents represented 11 ethnic groups Race x Consultation sent to range of race / religion and minority groups.
x In addition, sporting groups such as football, cricket and gyms were provided with consultation information, as it is recognised that these sports and facilities attract users from ethnically diverse backgrounds.
Religion or x See details provided above in ‘race’ section. x Respondents represented 11 religions / beliefs belief Sexual x 69% of respondents reported to be heterosexual; 1% orientation N/A gay; 1% bisexual; 29% did not wish to declare
EIA HWRC Review 2011 - 12 19 Protected Engagement mechanisms informed by initial EIA Consultation response Characteristic screening and interim EIA x Information was displayed at all Kent libraries – people with young x It is estimated that 14% of respondents have young children are often users of library services. children or are expecting a baby.
x Information was displayed and provided at all 9 Kent Gateways – residents more likely to be pregnant or who have young children are thought to be high users of Gateway services. Pregnancy and maternity x People with younger families are likely to be consumers of local newspapers. The consultation was advertised across all Kent leading press titles.
x Football clubs were provided with consultation information as it is understood that people with young families are members. Page 96 Marriage and civil N/A N/A partnership
EIA HWRC Review 2011 - 12 20 Final EIA Action Plan (February 2012)
This action plan has been developed to reflect the potential impacts should Members adopt some or all of the policies proposed in the HWRC review.
Protected Issues identified Action to be taken Expected outcomes Owner Timescale / Characteristic Cost implications Change in Communicate the outcome of the Outcome of HWRC Review Head of operational HWRC review and public consultation to made available to older people. Waste April / May policies following a older residents. Management 2012 AGE Cabinet decision. Develop and deliver an Implementation prepared and Waste implementation plan for introduction budget secured. Management of new operational policies, which (WM) budget provides for engagement with older – cost TBC customers. Page 97 Possible increase Provide comprehensive, targeted Older people receptive to From June in journey distance and timely communication to older communications delivered. 2012 and time for some people to support awareness of residents who have alternative HWRCs available to Older residents able to dispose Waste been using them in their locality. of their waste appropriately. Management Hawkinge3 and budget – cost Richborough Ensure information about all council Older people aware of TBC HWRCs to date. waste services is accessible to alternative HWRCs and able to older people to provide them with locate them easily. choice for their waste disposal needs. Decrease in Advertising of new HWRC during Older people aware of new Subject to journey time for build phase to inform potential HWRC, the nature of the service capital residents in service users of new facility. and the location. programme Tonbridge and Malling and north Promotion of the opening of the new Maidstone areas HWRC to older people within the with additional ‘catchment’ area. HWRC provided.
3 Remains within 20 minute drive time, equitable for residents elsewhere in east Kent. EIA HWRC Review 2011 - 12 21 Protected Issues identified Action to be taken Expected outcomes Owner Timescale / Characteristic Cost implications Ensure older Ensure preferred communication Communication of key To support all people are channels are utilised to information is received by older delivery. communicated with communicate with these target people with ease. In accordance appropriately to audiences, drawing on Mosaic to the capital meet their needs information and local data. programme and ensure and existing messages are site conveyed improvement appropriately. plans.
Change in Communicate the outcome of the Outcome of HWRC Review Head of April / May operational HWRC review and public consultation to made available to residents with Waste 2012 policies following a organisations representing disabilities through Management Cabinet decision. disability. representative organisations / Waste DISABILITY groups in Kent. Management
Page 98 Develop and deliver an (WM) budget implementation plan for introduction Implementation prepared and – cost TBC of new operational policies, which budget secured. provides for engagement with customers who have disabilities. Head of Cabinet approval Ensure accessibility for customers Improved accessibility for Waste for HWRC network with disabilities is fully considered at customers with disabilities. Management To support all infrastructure design stage for new HWRCs and delivery. development and for site improvements at existing In accordance improvements, will HWRCs. to the capital enable accessibility programme to be enhanced. Engage with disability groups within and existing Kent to help inform new site design site or improvements. improvement plans. Communicate site improvements / design to communities representing disability.
EIA HWRC Review 2011 - 12 22 Protected Issues identified Action to be taken Expected outcomes Owner Timescale / Characteristic Cost implications Accessibility to site Develop procedure to ensure Equitable access for customers Procedures for customers with customers with over-height adapted with disability vehicles requiring developed over-height vehicles are able to access HWRCs entry to HWRCs. April 2012 adapted vehicles. at their convenience and for KCC to communicate this appropriately to Customer relevant customers. engagement from May 2012 Possible increase Provide comprehensive, targeted Residents with disabilities able to From June in journey distance and timely communication to dispose of their waste 2012 and time to disability groups / organisations in appropriately. HWRCs, for some Kent Or individuals upon request), Waste residents who have to support awareness of alternative Residents with disabilities aware Management been using HWRCs available in the locality. of alternative HWRCs and able budget – cost Hawkinge and to locate them easily. TBC
Page 99 Richborough Distribute information about all HWRCs to date. council waste services to disability groups / organisations in Kent, so that people have choices as to how to dispose of their household waste.
Change in Ensure that the outcome of the Outcome of HWRC Review Head of operational HWRC HWRC Review and public made available to organisations / Waste April / May policies following a consultation is made available in groups representing ethnic Management 2012 Cabinet decision. alternative languages and groups in Kent. RACE appropriate formats for ethnically Waste diverse residents of Kent. Implementation prepared and Management budget secured. (WM) budget Develop and deliver an – cost TBC implementation plan for introduction of new operational policies which provides for engagement with ethnically diverse customers.
EIA HWRC Review 2011 - 12 23 Protected Issues identified Action to be taken Expected outcomes Owner Timescale / Characteristic Cost implications Change in Communicate the outcome of the Outcome of HWRC Review Head of April / May operational HWRC review and public consultation. made available. Waste 2012 PREGNANCY AND policies following a Management MATERNITY Cabinet decision. Develop and deliver an Implementation prepared and Waste implementation plan for introduction budget secured. Management of new operational policies – with (WM) budget regard to this protected – cost TBC characteristic HWRC site staff will continue to provide pregnant women with assistance for carrying and lifting waste materials, and ensuring children remain in vehicles for safety. Ensure that this is communicated sensitively in customer information. Page 100 Possible increase Provide timely communication to Pregnant women and / or those From June in journey distance support awareness of alternative with young children are able to 2012 and time for some HWRCs available in the locality. dispose of their waste residents who have appropriately. Waste been using Ensure information about all council Management Hawkinge and waste services is accessible to Parents aware of alternative budget – cost Richborough residents to provide them with HWRCs and able to locate them TBC HWRCs to date. choice for their waste disposal easily. needs. ALL PROTECTED To monitor To develop and implement Ensure accessibility to service Summer CHARACTERISTICS customer usage of monitoring tools. for people previously identified at 2012- IDENTIFIED HWRCs where risk of being negatively ongoing policies are To undertake regular reviews to impacted. implemented & analyse findings and take action identify any further where negative impacts are mitigating actions identified. required to prevent & mimimise impact upon customers exhibiting these protected characteristics.
EIA HWRC Review 2011 - 12 24 FINAL EIA - Sign Off
I have noted the content of the equality impact assessment and agree the actions to mitigate the adverse impact(s) that have been identified.
Senior Officer
Signed: Date: 21/02/12 Name: Caroline Arnold Job Title: Head of Waste Management
Directorate Equality Lead
Signed: Written approval provided via email on date below. Date: 21/02/12 Name: Akua Agyepong Job Title: Corporate Lead Equality and Diversity
.
Page 101 EIA HWRC Review 2011 - 12 25 APPENDIX i: Household Waste Recycling Centre public consultation delivery
CONSULTATION ENGAGEMENT The policies proposed in the consultation have the potential to affect every household in Kent. It was therefore important to devise engagement mechanisms to provide the opportunity for participation equally across Kent communities, being mindful of communication preferences and accessibility of information.
The consultation consisted of a questionnaire, available in both electronic and paper formats. Kent residents were made aware of the consultation and invited to respond using various communication methods to ensure a broad range of target audiences were engaged with in a proportionate manner.
The EIA shaped the engagement and participation mechanisms, identifying protected characteristics which had the potential to be negatively impacted by the proposed policies, as well as ensuring that particular attention was paid to engagement with minority groups in Kent.
MOSAIC ANALYSIS Mosaic, a customer segmentation tool, was used to understand the best way to engage with the residents in Kent. Within Kent, a bespoke Mosaic segmentation has been created using county specific data, whereby every postcode and household in Kent is classified as belonging to one of 69 types and 15 groups (Kent and Medway A – M). These groups identify clusters of individuals and households that are as similar as possible to each other, and as different as possible to any other group. They describe the residents of a postcode in terms of their typical demographics, their behaviours, their lifestyle characteristics and their attitudes. Mosaic was used in this instance to understand communication preferences to ensure that residents in Kent were informed about the consultation in a way that they are more likely to be receptive to.
In preparation for the consultation, a sample of postcodes for HWRC users were collated and profiled, to understand the make-up of the current customer base and their communication preferences. The profile of HWRC users was compared with the Mosaic profile of the Kent population as a whole, in order to understand those people more or less likely to use an HWRC user. This supported the development of targeted communication across all Mosaic groups to ensure a representative sample of Kent residents were engaged with.
Page 102 EIA HWRC Review 2011 - 12 26 The following communication approaches were developed and delivered based on Mosaic Analysis:
Direct Mail Mosaic was used to identify those residents in Kent more likely to be receptive to direct mail as a communication method. In order to determine the content of the direct mail, likely use of the Internet was also established (i.e. promoting a website would be inappropriate if Internet use was low).
As a result, a paper copy of the consultation questionnaire was sent to a random sample of residents belonging to K&M groups which were likely to be responsive to direct mail but less likely to have access to the internet. Residents were informed on the covering letter that their address had been selected at random and asked them to encourage others to respond also.
A second direct mail which took the form of a postcard with key points about the consultation and how to participate was sent to a sample of Kent households which were likely to be receptive to direct mail, but also likely to have access to the internet. The postcard signposted residents to the online consultation questionnaire whilst also giving them the option to request a paper copy (or alternative formats) if they preferred.
In light of the questionnaire proposing the closure of Hawkinge and Richborough HWRCs, the direct mail was up-weighted in the areas near these two sites.
Sports clubs/ societies Mosaic variables were used to understand which sports/ activities specific groups are likely to be interested in. As a result, posters were sent to sports clubs/ societies in Kent in specific areas based on the characteristics of the population in that area. For example, posters were sent to bowls clubs and golf clubs in area in Kent were there is know to be an older population and posters were sent to gyms where the communities are more likely to undertake this kind of activity.
Page 103 EIA HWRC Review 2011 - 12 27 OTHER COMMUNICATION APPROACHES
KCC website A dedicated web page (www.kent.gov.uk/hwrcconsultation) was created on the KCC website to provide consultation information and access to the online questionnaire. Furthermore, links to this page were provided on every Waste Management page regarding the HWRCs. An email address was also created specifically for any email correspondence regarding the consultation ([email protected]).
Gateways Each of the 9 Kent Gateways were provided with a supply of postcards, posters and paper copies of the consultation questionnaire, in order to give Kent residents another route with which to obtain a questionnaire should they be Gateway users. Gateways with ‘information screens’ carried information about the consultation.
Libraries A poster advertising the consultation along with a number of postcards and paper copies of the questionnaire were provided to each of the 99 KCC Libraries and 11 KCC Mobile Libraries.
Engagement at HWRCs Whilst it remained important to ensure that those residents that do not currently use the HWRCs are made aware of the consultation, providing information at the sites themselves direct to service users was very important. A sign advertising the consultation was installed at each of the 19 HWRCs on the 1st or 2nd of December 2011 and displayed for the full 10 weeks.
Furthermore, between 1st December and 4th December 2011, Waste Management officers successfully handed 5,500 postcards to HWRC customers promoting the consultation across all 19 HWRCs. These were handed out during the weekdays and weekend to ensure that different audiences were engaged with and at the earliest opportunity within the consultation period.
Press ads Mosaic was able to provide an indication of which areas in Kent would be receptive to press advertisements as a communication method. However, it was felt that it would be
Page 104 EIA HWRC Review 2011 - 12 28 more reasonable to run county-wide advertising to achieve the greatest reach, equality of access and achieve greatest value for money. In the week commencing 28th November 2011, a press advertisement was placed in all Kent Messenger paid for titles in Kent, as well as Thanet Extra, Sittingbourne Extra and Messenger Extras (formerly Gravesend, Dartford & Swanley Extra) which are free titles (as no dominant paid for title exists in these areas). A press ad was also placed in the Tunbridge Wells Courier and Tonbridge Courier.
KCC community engagement officers All 12 KCC Community Engagement Officers were sent an email prior the launch of the consultation to provide them with information should any members of their communities raise the subject at meetings or make an enquiry.
Key stakeholders As well as communicating with individual residents of Kent, key stakeholders were also engaged with to encourage them to contribute to the consultation process. The following stakeholders were engaged with: x All Kent parish and town councils were sent a paper copy of the questionnaire for the 1st December 2011 and were asked to make their residents aware of the consultation. Feedback was encouraged as individuals or as a combined response of the whole parish. Included within this was the Kent Association of Local Councils. x Waste Managers from all 12 Kent district councils and Medway Council were provided with a paper and electronic copy of the questionnaire and encouraged to respond to proposals via email. x The Environment Agency was provided with a paper copy of the questionnaire and encouraged to respond to proposals via email. x A paper copy of the questionnaire was also sent to KCC waste contractors encouraging them to respond via email. x Kent Fire and Rescue Service were also approached.
Page 105 EIA HWRC Review 2011 - 12 29 EQUALITY CONSIDERATIONS Equality groups Kent County Council is committed to ensuring that current and potential service users will not be discriminated against on the grounds of their social circumstances or background, such as gender, race, colour, ethnic origin, religion or belief, disability, gender identity, sexual orientation or age. As a result, a letter and / or e-mail was sent to over 150 equalities groups across the county to inform them of the consultation and to ask them to circulate the information to members of their groups / communities. These groups were informed that responses were welcome from individuals or as a group/ organisation. The following groups were contacted: x Age groups, including all age forums in Kent x BME groups x Disability groups x Gender groups x Refugee groups x Religion groups x Sexuality groups.
Furthermore, postcards were provided to influential members of the Gypsy and Irish Traveller communities to disseminate amongst their communities as it was felt that these had not been represented elsewhere.
All four KCC staff groups (Rainbow, Unite, Level Playing Field and Greenhouse) were sent an e-mail with the consultation information, again encouraging them to circulate the information to their members.
Alternative formats Prior to the launch of the consultation, the consultation questionnaire was produced in alternative formats: x Easy Read; x Large Print; x Audio format; and x Braille. Alterative language formats would have been accommodated if required, however, no requests were received.
Page 106 EIA HWRC Review 2011 - 12 30